THE COURT: Both sides can ask the witnesses if they have been keeping up with this, and I’ll have to decide what I’m going to do about it.

Okay. Mr. Prince.

(Mr. Prince took the witness stand.)

THE COURT: Good morning.

THE WITNESS: Good morning.

THE COURT: Okay. Day 31. This is the 11th, right?

MR. WEINBERG: Of the trial?

THE COURT: 7/11.

MR. WEINBERG: 7/11.

THE COURT: All right. You may continue, Counselor.

CROSS-EXAMINATION OF JESSE PRINCE (RESUMED)

BY MR. WEINBERG:

Q Now, in the vein that we just talked, the Judge

Page 1021

and I, have — since you have been back on the stand this week, have you met with any of the witnesses or prospective witnesses in this case?

THE COURT: Do you know who the prospective — does he know who they are?

BY MR. WEINBERG:

Q I think — well, the next witness is Frank Oliver, and then there’s Mr. Dandar. There’s some secret person that Mr. Dandar hasn’t told us about — maybe he’s told you — and the prior witnesses were Peter Alexander, what, Teresa Summers, Vaughn Young, Stacy Young, Bob Minton, other people — Brian Haney. Have you met with any of those people?

A Not anything for the purposes of — that’s been in relationship to this trial. I mean, I was here the day that Mr. Haney was here, and we had lunch when he was testifying. I think I was waiting outside the courtroom or something.

THE COURT: The real question is, Have you discussed with them their testimony or yours?

THE WITNESS: Oh, no.

BY MR. WEINBERG:

Q Have you discussed, since you’ve been back on the stand, your testimony with Mr. Dandar?

A No.

Page 1022

Q Or Mr. Lirot? I’m sorry. I had trouble with his name?

A No, Mr. Weinberg, I have not.

Q Or Ms. Greenway?

A No, Mr. Weinberg, I have not.

Q Okay.

A I followed the court instruction in that regard.

Q And have you had an opportunity to visit the — the —

THE COURT: Unless Ms. Greenway is a witness, she could technically — technically I suppose have chatted with her. If people under the rule —

First of all, he’s testified he ought not to be discussing his testimony; the Court instructed him so.

BY MR. WEINBERG:

Q Let me ask you this. I mean, have you eaten — I mean, have you visited with, you know, Ms. Greenway or Mr. Oliver or anybody like that?

A Yes.

Q Okay. Because they’re friends?

A Correct.

Q When’s the last time you saw Mr. Oliver?

A Last night.

Page 1023

Q What were you doing with him last night?

A We had dinner. I invited him to a barbecue.

Q Did you know that he was going to be testifying —

A Yes.

Q — after you?

A Yes.

Q And where was the barbecue?

A My house.

Q And who else was there?

11 A Mr. Lirot, Mrs. Greenway, my fiance.

THE COURT: It — really and truly, this is not your business. What is your business is whether —

MR. WEINBERG: I was going to ask one last question.

BY MR. WEINBERG:

Q And you all didn’t talk about the case?

THE COURT: That isn’t the question either.

It’s whether he discussed anything about his testimony. I mean, they can talk about the trial.

They can say — we’re all crazy to think that when most people get together, they don’t say, “What do you think? Is the case going to be ready for trial?” But the question is what’s going on here.

Page 1024

BY MR. WEINBERG:

Q Did you talk at all about your testimony or Mr. Oliver’s testimony?

A No. I followed the Court’s instruction in that regard.

Q Now, I touched on this a couple of days ago, but I want to go back for just a minute and see if we can focus more on the dates. After you left the Church of Scientology at the end of October, beginning of November of 1992, there came a time when, in Minneapolis, you became employed by a company called G & B. Is that right?

A Correct.

Q And that was a company — is a company that is run by a woman named Dana Hanson. Is that right?

A Correct.

Q And she is a public member of Scientology?

A To my knowledge at the time, yes.

Q All right. And you’d started working for her in March of 1994, thereabouts, correct?

A I’d say that’s a fair estimation of when I started working for her.

Q And at first your then-wife had been referred to her to work, right? Is that how it started?

A I believe, yes. I believe you’re correct in that.

Page 1025

Q And the reference came from a staff member in the Minneapolis Org?

A I’m not sure where the reference came from.

Q In any event, you began to work for this company, right?

A Correct.

Q And you stayed at the company until the fall of 1995, when you were fired, right?

A Incorrect. I was never fired from that company.

Q You left the company in the fall of 1995?

A Correct.

Q Now, during this period of time, Ms. Hanson was kind enough, for part of the time, to let you stay in her house. Right?

MR. DANDAR: Objection to relevancy.

THE COURT: Yes. Sustained.

BY MR. WEINBERG:

Q Well, during the time that you were employed by Ms. Hanson — oh, by the way, this company was run pursuant to Hubbard technology, correct?

A Not per se, but she wanted it to. She wanted me to run it according to Hubbard technology.

Q And —

A It hadn’t been like that before.

Q And briefly, that means what?

Page 1026

A Getting people to disclose intimate details about themselves because this was, you know, a Scientology belief that, you know, if you tell intimate details about yourself or things that you wouldn’t necessarily want made public, then it’ll somehow make you feel better and increase your production.

Q And —

A That’s one thing. Another part was to sit people down and have them study the writings of Mrs. Hanson concerning how the company should operate and make sure that they understood all the words that she had written.

And also, she wanted me to do like a class, a classroom for doing the TRs, the training routines that I mentioned earlier in my testimony that’s part of Scientology training —

Q Okay.

A — that kind of thing.

Q And the idea was the company would run more efficiently, correct?

A Correct.

Q Okay. Now, during the course of your year and a half or so with the company, there came a time when you admitted to Ms. Hanson that you had engaged in extensive unethical behavior, in violation of moral codes that were adhered to by Scientologists pursuant to this Hubbard

Page 1027

technology, correct?

MR. DANDAR: Objection. This is nothing but to try to embarrass and denigrate Mr. Prince —

THE COURT: What’s the point of this?

MR. WEINBERG: The point is that Mr. Prince said on direct that he couldn’t work because of the Church of Scientology, that he lost his job as a result of the Church of Scientology. That’s what he said.

THE COURT: That has nothing to do with this hearing. The objection is sustained.

BY MR. WEINBERG:

Q What was the reason that you left in October of ’95?

MR. DANDAR: Same objection.

THE COURT: I’ll allow that.

A I left because I didn’t want to practice — I didn’t want to do that — do the things, the Scientology things, in the company. I just wanted to be normal, just do what a company does, instead of adding a Scientology slant to it.

BY MR. WEINBERG:

Q All right. So the Church, no staff member, had anything to do with you being terminated from your job.

You just —

Page 1028

A I think I mentioned I was not terminated from my job, Mr. Weinberg.

Q When you terminated from your job, no staff member had anything to do with it.

A I couldn’t hear you. There was noise going on.

Q I said no staff member in any Church of Scientology had anything to do with you leaving your job. Is that right?

A No. That’s categorically false. Mr. Sutter from the Religious Technology Center, after I would not do the Scientological things in that company, together with Ms. Hanson —

THE COURT: This is just not relevant.

MR. WEINBERG: Okay. Well, I mean, a lot of that answer —

THE COURT: It is not relevant to this proceeding, so you’re not going to go into why he left the job. It just doesn’t matter.

MR. WEINBERG: Okay.

BY MR. WEINBERG:

Q Now, you said yesterday that you had — you accused the Church yesterday of having made you sign undated resignations, resignation letters, which were then dated on the date that you were busted from the RTC.

Correct?

Page 1029

A Correct.

MR. WEINBERG: Now, let me show you —

Do we have the resignation letters? Are they in evidence?

MR. DANDAR: While they’re looking for that, Judge, did you say this is Day 31?

THE COURT: If what Mr. Weinberg said yesterday, that that was Day 30, then this would be Day 31. I couldn’t keep up with it.

MR. WEINBERG: May I approach the clerk?

THE COURT: You may.

MR. WEINBERG: This is 242 (handing), your Honor.

BY MR. WEINBERG:

Q I’ve showed you what we’ve marked as 242 —

A Yes.

Q — Defendant’s 242. Can you look at those and tell me if those are copies of the three resignation letters which you signed on March 3rd, 1987?

A Yes, they are.

Q Now, you are familiar, are you not, with a dot matrix printer? Do you know what that is? Do you remember the printers back 13 or 14 years ago?

A Yes, I believe I know what you’re talking about.

Q Right. And this letter — you can tell that

Page 1030

these letters were typed on dot matrix printers. They were printed out on dot matrix printers. You can even see on the side, the column, some of the holes? Do you see that?

They line up exactly on the three letters, right?

A Okay.

Q And it’s impossible to have typed up a letter on a dot matrix printer years before and then run it back through and put a date on it years later. That’s impossible, isn’t it?

MR. DANDAR: Objection. Outside of his expertise.

THE COURT: Do you know the answer to that?

THE WITNESS: No. But I know the answer to why these documents have this date on here.

THE COURT: Okay. If he can’t answer that question, he can’t answer it.

MR. WEINBERG: I move these into evidence, your Honor.

THE COURT: All right.

THE WITNESS: Oh, can I have this?

MR. WEINBERG: Sure. She has it.

THE COURT: What is the number, please?

MR. WEINBERG: It’s 242.

BY MR. WEINBERG:

Q Now, in your direct testimony, you made a big

Page 1031

point about the CSWs, the completed staff work, you know, like the purchase orders. Do you know what I’m talking about?

A Yes, I do.

Q And —

A I didn’t make a big deal out of it. I think I explained it.

Q Well, the point was, you said that in order to — for the medical liaison office to buy, you know, chloral hydrate, you would have to have a CSW or purchase order issued. Correct?

A Right.

Q And then you drew some conclusion. Because there wasn’t any purchase order, your conclusion was that that hadn’t happened? Was that what your conclusion was?

A I do not believe that that was my conclusion.

Q In any event, you’re familiar, are you not, with cash floats? Do you know what that is?

A Sure.

Q And are you familiar with the policy that provides for a float for the MLO? Are you familiar with that?

A I am not.

Q Explain to the Court what a float is.

A Well, I mean, if you have a policy there, I mean,

Page 1032

I —

THE COURT: He just wants you to tell me what a float is, if you know.

THE WITNESS: I don’t.

BY MR. WEINBERG:

Q I thought you just said you did.

A Well, not in the — I don’t think — maybe I misspoke, because I don’t understand the context you’re talking about float here.

MR. WEINBERG: All right. I’ll have it marked.

Could you mark this as 243, I believe.

This would be 243, your Honor (handing).

THE WITNESS: Thank you.

BY MR. WEINBERG:

Q Now, I’ve handed you a — Defendant’s 243, which is Flag Order 3082R, November 15th, 1971, with regard to medical finance. And do you see that this policy reinstates in every Sea Organization the use of a $1,000 medical float? Do you see that?

A Yes, I do.

Q And do you understand what that means?

A Yes, I do. But this does not negate someone else that has a medical emergency, as stated in that CSW exhibit that we put in for medical emergencies, of what it has to

Page 1033

go through.

Q Well, do you understand that what this is saying is that for every Sea Organization, including — which would include Flag Services, correct, Fort Harrison?

A Correct.

Q Right. That for every organization, the MLO, the medical liaison office, has a $1,000 float from which they don’t have to issue these CSWs and purchase orders and can go get what they need? Do you understand that?

A Well, hang on a second, because I’m looking at this second page here, and it says since the medical officer has the authority in the Org more than anyone else under need of these purchases, he does not need division reapproval. He does not have to have a CSW for his money. Division 3 just disburses the money each time. A simple red purchase order stating $1,000 for a medical float is sufficient to get the money.

Now, what this is specifically referring to is a medical officer having this float, but there’s another policy letter in Scientology that’s in Division 3 that has to do with accounting. Even though this medical officer would have this float, he would still have to account in detail where the last $1,000 went as well.

Q Well, look at under “essential data.” Do you see where it says this policy — this medical float policy is

Page 1034

established to prevent the medical officer from having to spend much time or worry on finance?

A Yes.

Q Do you understand that the whole concept of every time I had to go get chloral hydrate for a parishioner that needed it, that I would have to fill out some CSW, that that might not be a very efficient way to help people and that that’s what this float policy is all about?

A Well, you know, I understand what you’re saying in theory and, you know, I don’t — I really don’t think it’s a common practice.

THE COURT: Are you saying that when you go back and get more — $1,000 float money that they’re going to want to see what you spent the money for?

THE WITNESS: Yes. Yes, your Honor.

THE COURT: And how are you going to account for that? With receipts or what?

THE WITNESS: Yes, your Honor.

BY MR. WEINBERG:

Q Now, have you ever been a medical liaison officer?

A No, I have not.

THE COURT: I mean, this sounds to me like a petty cash fund of sorts.

MR. WEINBERG: That’s exactly —

Page 1035

THE COURT: When you have a petty cash fund, you still — if it’s a $1,000 petty cash fund, you’re going to have to show somebody what it is you spent the money on.

MR. DANDAR: I also object. The last sentence on this document talks about it’s only for the crew. They hadn’t mentioned anything about public members.

THE COURT: Well, you can bring that up on cross-examination.

MR. DANDAR: All right.

MR. WEINBERG: I was just raising this because of the testimony on direct, that you needed a CSW. This policy says you don’t need a CSW.

THE COURT: I frankly didn’t even remember it, so . . .

MR. WEINBERG: You do now, right?

THE COURT: I do now.

MR. WEINBERG: And then I’ll just show you —

Then I’ll mark, just so it’s in the record the — as the next exhibit.

THE CLERK: 244.

MR. WEINBERG: 244, take one second (handing to Court and witness).

Page 1036

BY MR. WEINBERG:

Q The Modern Management Technology Defined: Hubbard Dictionary of Administration and Management. You know about that dictionary, right, Mr. Prince?

A Yes, I do.

Q If you go to “medical float,” do you see on page 329, it says: “With this float, the medical officer buys doctor-dentist-medical-health specialist visits and treatment, laboratory analysis, X rays, medical equipment essential for a person’s health, medicines, prescriptions, and transportation.” Do you see that?

A Yes.

Q So something like a prescription for chloral hydrate would be covered by the medical float, would it not?

A This references this same Flag order. I gave testimony that a Flag order has to do with Sea Org personnel. It has to do with people that are on staff in the Sea Org.

Q So — so the MLO officer has to get a purchase order to go get chloral hydrate for a parishioner who is staying at the Fort Harrison, but if he or she doesn’t — if a Sea Org member is at the Fort Harrison? Is that your testimony?

A My testimony is the evidence that you’ve given me

Page 1037

here states specifically that this is how it is done for staff members. The public, being a paying public, certainly have different policies.

THE COURT: To be candid with you, I think it’s been conceded that — by somebody that Lisa McPherson should not have been to the hotel. Hasn’t that been conceded?

MR. WEINBERG: Well, I don’t think conceded.

I think people were trying —

THE COURT: To suggest that it really ought not to have been taken care of —

MR. WEINBERG: It would have been a smarter thing to be in a different environment.

THE COURT: Right. So you have to assume that the medical that they’re talking about in this — I’ll ask Mr. Prince this.

You have to assume that normally it’s going to be Sea Org members who are going to be taken care of because they’re the ones that would be living in a Scientology facility.

THE WITNESS: Correct.

THE COURT: But at some place like Flag, where they have maybe — I guess you have to be a Sea Org member to come there and take the technology courses that they offered.

Page 1038

THE WITNESS: No, you don’t have to be —

THE COURT: Right. So if somebody is there — there, and they have to get a — I mean, I don’t know what — they get sick and somebody is called in and they need some minor medicine, I would assume that they would allow this policy to govern, rather than have to go through all the harangue of whatever it was you were talking about.

But I think that whatever it is, you’re going to still, nonetheless, account for whatever it is you bought out of your petty cash fund or your float fund or whatever you want to call it.

THE WITNESS: Sure. And the other thing, your Honor, is that in no way will a Scientology organization pay the medical expenses of a public paying staff member, a public person coming in, using services in Scientology.

You know, the money works the other way. The public gives the money to Scientology. Scientology doesn’t then —

THE COURT: Well, we know they were using Ms. McPherson’s money to pay for certain things because she eventually ran out.

THE WITNESS: Correct.

THE COURT: So presumably everything was subject. I mean, if she was really in a bad

Page 1039

situation, a psychotic, where she couldn’t — you know, they apparently were free to use her funds, I guess.

THE WITNESS: Yes.

THE COURT: So you can’t really tell us, under the circumstances that we’re dealing with here, whether chloral hydrate was necessarily purchased out of the float money or whether it was purchased with this CSW.

THE WITNESS: Correct.

THE COURT: Would that be fair?

THE WITNESS: Yes, your Honor.

MR. WEINBERG: Just a few more questions, one more area.

BY MR. WEINBERG:

Q Back to the gun situation just for a moment.

Yesterday when we talked about this or the day before — I’ve sort of lost count now — you sort of suggested that it was more of a — of a joke, that you really weren’t that serious.

THE COURT: What was a joke?

BY MR. WEINBERG:

Q That you weren’t really threatening anybody.

THE COURT: What are you talking about?

MR. WEINBERG: Oh, I’m sorry, the gun, when

Page 1040

he says he pulled the guns on David Miscavige.

A I didn’t say anything about a joke. I said I did it out of self-protection.

BY MR. WEINBERG:

Q All right. So —

A That’s the testimony that I gave from this stand.

Q Well, I thought I heard you say that you didn’t really threaten anybody.

A I can’t help what you thought you heard, but I can tell you right now that when — after — what I testified to in this courtroom is that after those people grabbed me and I got away from them, I went to my room and got these weapons to protect myself.

It wasn’t a joke to me at that point.

Q And when you first told — do you remember when you first told this story about guns? That was in the FACTNet deposition, which was the first deposition I think — was that the first deposition you gave after you became a witness against Scientology?

MR. DANDAR: Objection to form.

THE COURT: No, that’s all right.

MR. DANDAR: All right.

THE COURT: Overruled.

A I’m not sure.

BY MR. WEINBERG:

Page 1041

Q All right. Do you remember in that deposition that you said something to the effect that bodies were going to start dropping?

A If you have it, you know, I’d like to see it.

Q Okay.

A If you just have it, you show it to me, and I’ll tell you what I said.

Q We’ll play a short clip, you’ll have it, and then I’ll have a couple of questions.

A Okay.

HE COURT: A short clip from what? A deposition?

MR. WEINBERG: Of his deposition. It’s his deposition.

THE COURT: In this case?

MR. WEINBERG: No. It’s his deposition in the FACTNet case. It will take just a minute, I think.

MR. DANDAR: Apparently need it brighter.

MR. WEINBERG: I’m amazed she can pull this stuff up.

THE WITNESS: Right in this room, I’m having a difficult time. I think I’d better go around.

THE COURT: Sure. Wait a minute.

MR. WEINBERG: Wait just one second.

Page 1042

(The witness left the stand,)

THE WITNESS: Okay.

THE COURT: Okay.

(The tape was played as follows.)

FROM THE DEPOSITION OF JESSE PRINCE DATED AUGUST 20, 1998

A And I went to my room, where I had a loaded .45 and a loaded Mini 14, and I came back to David Miscavige’s office with those guns. And I said, “Which one of you wants to fuck with me now?”

BY MR. ROSEN:

Q And what happened? I’m sitting here with bated breath thinking — to hear the end of the story.

A Well, do you want me to tell it or do you want —

Q No, I’m (unintelligible) the answer to that question that you raised.

A Well, I’m confused now. What question did I raise?

Q You posed a question to Mr. Miscavige that “which one of you wants to F with me now?”

A Right. So at this point Vicki comes running out:

“Jesse, no, no, no, it’s all been sanctioned by Annie Broker. She knows about everything. And Pat Broker. She knows about everything. Don’t do this.”

Then here comes David Miscavige. He completely

Page 1043

changes his tune now: “Oh, Jesse,” you know, “we’ve been friends and we’ve gone through so much. Let’s not go here.

And I stood there looking at them with my guns in my hand, wondering. You know, like you can pat a snake on the head, but as soon as you pull your hand back, he going to bite. And I was wondering if that was going to happen to me as I’m sitting here with these guns.

And, you know, David is like pleading. Then it turns into a situation like, “Well,” you know, “we’ve got lots of guns too.”

And I said, “What the hell do you all want to do, have a shootout? Because I’ve got guns here, and bodies are going to start dropping.”

(End of tape. The witness returned to the stand)

MR. DANDAR: I object. It’s apples and oranges. It doesn’t even go to try to impeach the witness.

MR. WEINBERG: Well, first —

THE COURT: I don’t know what the purpose was, so we’ll hear now.

BY MR. WEINBERG:

Q Yesterday or the day before, July 9th, when I

Page 1044

asked you the question about whether you threatened to kill Mr. Miscavige, you said, quote, “I didn’t threaten to kill Mr. Miscavige.”

Now, when you told that story to Mr. Rosen at that August 1998 deposition, you said in front of Mr. Miscavige, you know, “Bodies are going to start dropping,” or something like that. Right? I mean, you said that —

A The video speaks for itself, and I don’t contest it. I mean, that’s — what I said is what happened, is what I meant. So you can take it any way you want.

Q Now, when you said a Mini 14 —

THE COURT: A what?

MR. WEINBERG: A Mini 14.

THE COURT: What do we care about this, about these guns?

MR. WEINBERG: About —

THE COURT: About something that went on between him and — way back when.

MR. WEINBERG: No, it’s just the opposite, your Honor. We don’t believe this incident ever happened and that he just made this up for reasons that one can only imagine when he told this story for the first time in August of 1998. But, your Honor, I mean —

Page 1045

BY MR. WEINBERG:

Q Let me ask you. A Mini 14 is an assault rifle, right?

A Correct.

MR. WEINBERG: Mr. Bailiff, could I possibly have our model there?

This is just a replica.

THE COURT: Okay.

MR. WEINBERG: It’s plastic. It’s plastic.

It’s not real.

MR. DANDAR: I just wish — I just wish the St. Pete Times was here with their camera to see this.

I think this is an unbelievable game —

THE COURT: Is that an objection?

MR. DANDAR: — of showmanship. It’s irrelevant.

THE COURT: What is the point?

BY MR. WEINBERG:

Q (Showing) Is that what you’re talking about?

Something like that?

A Similar to, but not quite.

MR. WEINBERG: All right. I’m going to give you this back.

BY MR. WEINBERG:

Q And you still contend that that’s what you pulled

Page 1046

on Mr. Miscavige and the other twelve people that were there. Right?

A Mr. Weinberg, I stand behind the testimony that I’ve given about that incident in the past and anything I’ve said —

Q All right.

A — in this hearing.

Q And then they just let you go right back to your room and put the guns in your room?

A Correct.

Q And they didn’t take them away from you?

A Correct.

Q And they just stayed there for the next, what, five years?

A No. I eventually sold the Mini 14.

MR. WEINBERG: Okay. I don’t have any further questions, your Honor.

THE COURT: All right. Redirect?

MR. DANDAR: Yes.

REDIRECT EXAMINATION

BY MR. DANDAR:

Q Well, we ought to pick it up right where Mr. Weinberg just left off.

(Mr. Weinberg spoke to Mr. Dandar off the record.)

Page 1047

MR. DANDAR: Do you want me to wait?

MR. WEINBERG: That’s fine. I just don’t want to interrupt you.

BY MR. DANDAR:

Q When you had these two real guns loaded as you described when you were being, quote, busted, unquote, Mr. Miscavige came right up to you while you held the two guns in your hands, correct?

A Correct.

Q And did you or he laugh?

A Laugh?

Q Laugh.

A Like laugh?

Q Yes, like laugh.

A No.

Q Did Mr. Miscavige say — indicate to you any fear whatsoever?

A No.

Q And then you turned around and walked back to your room?

A Correct. I believe he may have even followed me there. And we then proceeded to that area of the ship where we saw the pictures with the swimming pool, with the mast, and we had a conversation there.

Q Did you sit around the pool?

Page 1048

A Well, actually, there’s an area inside that’s air-conditioned, has a bar in there, and we actually sat in there and drank cold water and ate fruit.

Q And when Mr. Weinberg — or, you said that Vicki Aznaran, the president of the RTC, told you that this had all been sanctioned by Annie and Pat Broker, did she accompany you to the RPF after that?

A Yes, and other people for sure.

Q Because she took the Annie and Pat Broker side, rather than the David Miscavige power struggle side?

A Correct.

Q You’re going to the RPF, Mr. Prince. Did it have anything to do with any mistakes you made in applying the tech of Scientology?

A Absolutely not.

THE COURT: What does this all have to do with anything I’m hearing?

MR. DANDAR: Just trying to straighten out some misconceptions. My computer just went onto standby. That’s not what I wanted to happen. All right.

BY MR. DANDAR:

Q Now, when you left Scientology, did you just walk out the door in ’92?

A No.

Page 1049

Q How did you leave?

A I had to basically sign a release saying that Scientology has never done anything wrong with me and has no liability for anything that I may be suffering then or could realize in the future and on and on and on —

THE COURT: Wasn’t that release introduced yesterday?

MR. DANDAR: Yes.

THE WITNESS: Yes.

THE COURT: So it said whatever it said.

MR. DANDAR: Well, I wanted to ask him a question about it, and you can see my paralegal is not here, so I’m flying.

BY MR. DANDAR:

Q That release says that you were releasing the Church of Scientology from any and all damages for valuable consideration. There’s two or three paragraphs that say that.

A M’hum (affirmative).

Q What valuable consideration did you receive from the Church of Scientology to sign that release?

MR. WEINBERG: It was asked and answered.

He explained —

THE WITNESS: No, I never answered this.

THE COURT: Just a second.

Page 1050

MR. WEINBERG: Objection, asked and answered

by Mr. Dandar. I didn’t go back into it. It’s beyond the scope. But he already — Mr. Prince already explained how much money he got in return for signing the release on direct.

THE COURT: He did?

MR. WEINBERG: Yes. He said —

THE WITNESS: No, I didn’t.

MR. DANDAR: Shhh.

MR. WEINBERG: I thought he said a thousand plus dollars.

THE COURT: I don’t remember it, so I’m going to allow him to ask it. I don’t remember it.

MR. WEINBERG: Okay. I might have brain drain.

MR. DANDAR: I think you’re talking about some meeting in December of ’94.

MR. WEINBERG: No, I don’t think so.

THE COURT: That was more than a thousand.

THE WITNESS: Twenty-seven.

MR. WEINBERG: I really think he did, but it doesn’t matter.

THE COURT: All right.

BY MR. DANDAR:

Q Well, did you receive anything of consideration

Page 1051

to sign those releases?

A I think I received $2,000.

Q Okay. From whom?

A Good question. Marty just handed me the money.

Q Well, do you have any idea why it’s not mentioned in the release?

A I do not.

THE COURT: Most releases don’t tell you what. Most releases say “ten dollars and other valuable consideration,” don’t they?

MR. DANDAR: Not the ones that I’ve seen, Judge.

THE COURT: Most of the ones I’ve seen do, because I always wondered why they pick ten dollars.

BY MR. DANDAR:

Q Mr. Prince, how is it that Ms. Dana Hanson wanted to — picked you to come into her public business and set up her business to run the Hubbard tech?

MR. WEINBERG: Objection as to competency.

I mean, how is it that this woman —

THE COURT: I’ll sustain that. Quite frankly, I suspect that he’s already testified he was one of the premier experts on the tech. So I mean, I think I can assume that.

MR. DANDAR: Okay. If you can assume that,

Page 1052

I’ll go on.

BY MR. DANDAR:

Q Now, Mr. Prince, you were —

THE COURT: I can’t assume that, but, I mean, that is the testimony that he has put forth.

MR. DANDAR: Okay.

THE COURT: So . . .

BY MR. DANDAR:

Q Mr. Prince, is there any other reason as far as you know — without telling us what other people said — is there any other reason as far as you know as to why Dana Hanson hired you, other than your expertise on the tech?

Q Mr. Prince, you wanted to tell Mr. Weinberg a little while ago why the date of March 3, 1987, appears on all three resignation letters which is Defendant’s Exhibit 242. Why does the date appear on there?

Page 1053

A Because after me and Mr. Miscavige had our little chat on the ship area after the gun incident, he said, you know: “We have your undated resignation, but just help us,” you know, “do everything right now.” You know: “We’re talking again. You’re going to take this fall; you’re going to do this. Would you please just do it again and sign these new ones?”

And I said, “Yes, I’ll do it.”

So that’s why these are signed this way.

Q So there exists other resignation letters that are undated?

A Yes, correct.

Q Have you seen those? Have they been produced to you ever?

A Not today.

Q Have you ever seen them before this?

A Sure.

Q Where?

A In the Religious Technology Center in my office, where I signed it. I also saw it in David Miscavige’s office on the day that I was removed from the executive position of Religious Technology Center.

Q Okay. So on the resignation letters that are in evidence, those are the ones you actually signed on March 3rd of 1987?

Page 1054

A Correct.

Q Okay. And you did that because your friend David Miscavige asked you to do it?

A Correct.

Q You weren’t threatened and forced to do it?

A Correct.

Q Were you being a good Scientologist when you signed that?

A Absolutely.

Q All right. Now, Mr. Houghton, who is a defendant in this case, who is in the MLO office, who is the one that came up with the idea of using a syringe to get aspirin and Benadryl —

MR. WEINBERG: Objection, your Honor. First of all, to the form; he’s just testifying.

Secondly, he’s misstating the testimony.

And thirdly, it’s beyond the scope of my cross-examination. I didn’t ask anything about Mr. Houghton.

THE COURT: I suspect he’s going to go back to the CSW that you felt compelled to raise in some fashion.

MR. WEINBERG: That’s fine. But then —

MR. DANDAR: How do you know that?

MR. WEINBERG: — I object to the form. Then I object to the form, as he’s just making a

Page 1055

speech.

THE COURT: Your objection to form is overruled because he’s not. He’s trying to provide some background to see if this witness can answer a question.

BY MR. DANDAR:

Q Mr. Houghton stated on page 71 of his deposition, where the question begins on line 18, as follows.

Question —

THE COURT: You folks back there, I can hear you clear up here, so it must be disconcerting to Mr. Dandar. So keep your voices down. Or you may step out of the room at anytime you need to speak in a loud voice.

Go ahead.

BY MR. DANDAR:

Q Question: “And where did you get the money to buy the prescription?”

Answer: “I got it from Alain Kartuzinski.”

Question: “And why did you go to him to get the money?”

Answer: “I didn’t have the personal funds to pay for it. I didn’t know. I don’t know exactly why I went to Alain. I don’t know what events led me up to getting the money from Alain, but I do know that’s where I got the

Page 1056

money.”

The question is, Is Mr. Kartuzinski, back in November and December of 1995, pursuant to his testimony in this case, part of the MLO?

A No.

Q What was he?

A He was the Senior CS —

THE COURT: I’ll tell counsel what you really don’t have to do is ask this witness that. I would know that.

MR. DANDAR: Sorry.

THE COURT: You can save a lot of this for closing argument.

MR. DANDAR: All right. There’s so much of that.

All right. That takes care of this part.

Let’s put this away.

THE COURT: Is this a witness, by chance, that has just come in?

A SPEAKER: (Shook head negatively.) No, your Honor.

THE COURT: Okay. Welcome then. I didn’t want somebody to come in that was maybe going to testify.

BY MR. DANDAR:

Page 1057

Q All right. Mr. Prince, in your tenure in Clearwater at the Lisa McPherson Trust, did you ever see the Church of Scientology picketing the Lisa McPherson Trust?

A Absolutely. You know — yes. Yes, many times.

Q Would they do it in front of the building, the office?

A They would do it in front of the building. They would do it inside the building. There’s many police reports of Scientologists running and screaming, disrupting activities. Again, my friend — my good friend, Judge Penick, can speak about that. And we watched videos for days. He would be a great witness about that.

Q Okay. All right. Do you know if anyone from the Lisa McPherson Trust hired private investigators to follow Church members around?

A Never.

Q Go to their homes and picket their homes?

A Never.

Q Pass out leaflets in their neighborhood?

A No.

Q Now, even though you left the Church of Scientology, have you ever divulged the confidential PC folders of the people that you either audited or were a case supervisor over?

Page 1058

A No, I have not, never.

Q Now, Mr. Weinberg went back and talked to you about your deposition that you gave on behalf of Religious Technology Center, where their former attorney, Joseph Yanny, was suing them or RTC was suing him. I’m not sure.

Do you remember which way that was?

A I don’t remember which way it was going.

Q Okay. But anyway, that was back in 1989, while you were still in your demoted status?

A You know, that had been some years past that, yes.

Q Okay. And when you met — you said you met with Mr. Earle Cooley, the attorney for RTC, before your deposition commenced?

A Correct.

Q Do you also recall meeting with a person by the name of Lynn Farney?

A Yes.

Q And the reason why I know this is it’s in your deposition copy that Mr. Weinberg gave me. Before today — in fact, as you sit here today, have you ever seen a copy of that deposition?

A No.

Q That deposition is dated September 11th of 1989.

Mr. Weinberg questioned you in your deposition in this case

Page 1059

that was taken in ’99, ten years after the RTC deposition.

Do you remember him questioning you about that deposition?

A Yes.

Q Did he give you a copy of that deposition back then?

A No.

Q Now, Mr. Farney, do you know — back at the time that he and Mr. Cooley, the attorney, met with you before the RTC deposition, do you know what position he had?

A Mr. Farney had been on a Rehabilitation Project Force with myself. Mr. Lynn Farney is a person that I used to create and establish the Office of Special Affairs at International. I had —

MR. WEINBERG: Your Honor, he just asked him what position he was in at the time that he supposedly had this meeting with him. Now we’re getting the whole history. Can he just answer the question, please?

THE COURT: Sustained.

BY MR. DANDAR:

Q At the time of his deposition, what was his position?

A Mr. Farney was working in OSA International. It was my belief that Mr. Farney was working in OSA International.

Page 1060

THE COURT: I’m sorry, I must have missed the beginning of this. What did you initially ask him? If Mr. Farney was —

MR. DANDAR: Part of the meeting preparing Mr. Prince for deposition in the RTC case.

THE COURT: Okay.

MR. DANDAR: RTC slash Yanny, Y-a-n-n-e-y.

THE WITNESS: Y-a-n-n-y.

MR. DANDAR: Okay. Thank you.

BY MR. DANDAR:

Q Mr. Farney is someone that you worked with in establishing the Office of Special Affairs?

A Correct.

Q Do you remember what year that was?

A ’84. ’83, ’84.

Q Okay. And are you aware that Mr. Farney is also the person who met with all the staff members after Lisa McPherson’s death?

MR. WEINBERG: Objection, your Honor —

A No, I was not aware of that.

MR. WEINBERG: Objection to form. He’s testifying.

THE COURT: True. Sustained. However, he wasn’t aware of it, so —

MR. WEINBERG: I understand. It’s just —

Page 1061

THE COURT: Remember, questions aren’t evidence, only the answers.

BY MR. DANDAR:

Q Now, in that meeting before your deposition, who instructed you to avoid telling the truth in your deposition?

A Mr. Rathbun and Mr. Cooley.

THE COURT: Is it Rathburn or Rathbun?

MR. WEINBERG: Bun.

THE COURT: Bun.

THE WITNESS: Rathbun.

THE COURT: B-u-n.

MR. WEINBERG: Right.

MR. DANDAR: And it’s Ms. Brooks, not Mrs. Brooks. Never mind.

MR. WEINBERG: R-a-t-h-b-u-n.

MR. DANDAR: I’m sorry. All right.

BY MR. DANDAR:

Q Did it surprise you when Mr. Cooley and Mr. Rathbun were giving you instructions on not telling the truth?

A No, it did not.

Q And why is that?

A Because it’s expected.

Q Why is that?

Page 1062

A Because you have to protect Scientology. You have to protect — you know, it’s like placing Scientology and Scientologists at risk being a crime. You have — you are expected as a member of the Church of Scientology to do and say whatever you have to to preserve Scientology, to preserve its leaders.

Q Is that a written policy?

A Probably.

Q And Mr. Yanny —

MR. WEINBERG: Well, your Honor, could we just identify that policy if that’s a written policy?

He said “probably.”

THE COURT: I assume probably he couldn’t tell us —

MR. WEINBERG: All right.

THE COURT: — or he would have given us a number.

MR. WEINBERG: Okay.

BY MR. DANDAR:

Q Can you tell us — without giving a number, but can you tell us generally what policy you’re talking about?

A As I sit here today without the materials, I could not, but I could certainly submit a declaration on it at a later point.

Q All right. What is an acceptable truth?

Page 1063

MR. WEINBERG: Objection, your Honor. I didn’t ask him about —

THE COURT: Right.

MR. WEINBERG: Beyond the scope.

THE COURT: I think he already — didn’t you already ask that on direct?

MR. DANDAR: I did, I did.

BY MR. DANDAR:

Q Now, you said —

THE COURT: Didn’t you also testify about the greatest good for the greatest number?

THE WITNESS: Yes, your Honor, I did.

THE COURT: So we’ve heard, I think, a lot of that.

MR. DANDAR: You have, I’m sorry.

BY MR. DANDAR:

Q Were you working for RTC at the time of that deposition in 1989?

A No, I was not.

Q Well, Mr. Yanny was the former president — or, attorney for RTC, correct?

A Correct.

Q Why was he suing RTC? What was that litigation about?

A You know, what I recall about that is that when

Page 1064

Joseph Yanny was hired, he was hired by myself and Ms. Aznaran as the lead counsel for the Religious Technology Center. When he was hired —

THE COURT: Who was? I’m sorry.

THE WITNESS: Mr. Joseph Yanny, the attorney that was hired.

THE COURT: Mr. Yanny was an attorney?

MR. DANDAR: Yes.

THE WITNESS: Yes.

THE COURT: Oh, okay.

MR. DANDAR: In fact, Judge —

Did we mark that as an exhibit at deposition? I’d like to have that marked as an exhibit since it was used. But Mr. Yanny is the one that actually took over questioning of Mr. Prince on the pertinent pages that Mr. Weinberg pointed out, although Mr. Yanny had his own attorney there. He took it over because Mr. Yanny — like me and Mr. Lirot. I have all this stuff in my head and I know what’s going on.

So the transcript — and I’d like to make that — and I will make it an exhibit if it’s not — shows that Mr. Yanny took over the questioning of Mr. Prince in that 1989 deposition.

THE COURT: Normally we don’t use as an

Page 1065

exhibit something that is just strictly used for impeachment purposes.

MR. WEINBERG: That’s why I didn’t do it.

THE COURT: Right.

MR. DANDAR: All right.

THE COURT: But if you want to make it an exhibit, why, that’s your — you can try to do that.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Mr. Prince, you stated to Mr. Weinberg —

MR. WEINBERG: Your Honor, let me object. I mean, let me intercede for just a second. Just so it’s clear, Mr. Yanny was the party, was the plaintiff. And I think that was clear, but I’m not sure if it was.

THE COURT: I got it.

MR. WEINBERG: RTC was the defendant.

THE COURT: I didn’t realize Mr. Yanny was a lawyer. That’s why I —

MR. WEINBERG: Yes.

BY MR. DANDAR:

Q So you hired Mr. Yanny to be the attorney for RTC?

A Mr. Yanny was — yes, I did, to be the lead counsel for RTC. RTC had other attorneys, but Mr. Yanny

Page 1066

was hired to be the lead counsel for the Religious Technology Center at that time.

Q And is it for any particular case?

MR. WEINBERG: Object. Your Honor, I believe this is all beyond the scope. All I did was impeach him on his false testimony, which he admitted was false in that deposition. Now to get to the history of that lawsuit or Joseph Yanny I think is beyond the scope and not relevant to this proceeding either.

THE COURT: I would tend to agree with that, Counsel. You know, if you think it’s relevant and there’s something you can tell me about this, I’ll listen to you. But it’s just another one of these lawsuits, many, many lawsuits.

MR. DANDAR: Okay.

BY MR. WEINBERG:

Q Mr. Prince, do you know whether or not any of the allegations made between RTC and Joseph Yanny had anything to do with Mr. Yanny perjuring himself or suborning perjury?

THE COURT: That would be relevant.

A I don’t know. I don’t remember it.

BY MR. DANDAR:

Q You don’t?

Page 1067

A No.

Q All right. Now, did Mr. Yanny have anything to do with any of the Wollersheim litigation?

A Yes, he did. The Wollersheim —

MR. WEINBERG: Objection. That was a yes or no question, and to — if we get into the details, I’m going to object because it’s beyond the scope and it’s not relevant.

THE COURT: That would be true.

MR. DANDAR: Except he brought up the question, Mr. Weinberg did, about Mr. Prince’s testimony of destruction of the PC folders.

THE COURT: Oh, right.

MR. WEINBERG: And I impeached him on it with the Yanny deposition. He admitted it. He said he lied in the deposition. That’s all I used it for.

THE COURT: Well, I think at this point we’ll see what his question is.

MR. WEINBERG: Okay.

BY MR. DANDAR:

Q Was Mr. Yanny involved in representing RTC against Mr. Wollersheim?

A Yes.

Q And was Mr. Yanny involved when Mr. Wollersheim’s PC folders were destroyed?

Page 1068

A He had no personal knowledge of it.

Q Was any attorney for Scientology involved in that in any degree?

A The only one that I know of that would have had information about that would have been Mr. Earle Cooley.

MR. WEINBERG: Objection, “would have had.”

I mean, is he saying he did have?

THE WITNESS: I can explain if you would like me to.

BY MR. DANDAR:

Q Go ahead. Explain it.

A The decision to do this was made in a conference room at Author Services with myself, Vicki Asnaran, Mr. Rathbun was there, Mr. Cooley was there, and this all has to do with —

And we were sitting in the conference room discussing it. Mr. Starkey may have been there, Mr. Norman Starkey.

THE COURT: This is when you discussed

Page 1069

destruction of these records?

THE WITNESS: Yes, your Honor.

THE COURT: So Mr. Cooley would have heard this? Is that what you’re saying?

THE WITNESS: Yes, your Honor.

THE COURT: All right.

BY MR. DANDAR:

Q And whose idea was it to destroy the records?

A As best as I can recall, it was Ms. Aznaran that said, “We have to destroy the folders.” Mr. Miscavige and everyone else agreed, so that’s what was done.

Q And did the folders contain information that would hurt the Church of Scientology?

A Yes, it — apparently, you know, that’s what they felt.

Q Okay.

THE COURT: That’s what you felt too. Right? You were there.

THE WITNESS: Well, I had actually never seen Mr. Wollersheim’s Preclear folders. I had never audited him.

THE COURT: But you didn’t have a problem destroying it.

THE WITNESS: Correct.

BY MR. DANDAR:

Page 1070

Q And why didn’t you have a problem destroying his records?

A Because, like every good Scientologist, you have to protect Scientology. You have to protect the integrity of Scientology, its leadership, so that it would carry on because it’s the greatest good. Scientologists believe that Scientology is man’s only answer to freedom.

Q Now, did you have to understand — I’m sorry.

Did I interrupt you?

A No, go ahead.

Q Did you understand at any point in time there was actually a court order to produce the entire PC folders of Mr. Wollersheim after the Church only produced a little bit of it?

MR. WEINBERG: Objection, relevancy. He’s already — and beyond the scope and all that —

THE COURT: Sustained.

MR. WEINBERG: — other stuff.

THE COURT: I’m sustaining it as beyond the scope.

MR. DANDAR: Okay. Well —

THE COURT: I mean, frankly, I think we’ve already been over this.

MR. WEINBERG: I do too. That’s why I objected.

Page 1071

THE COURT: I don’t need to hear it several times.

BY MR. DANDAR:

Q Well, Mr. Prince —

MR. WEINBERG: Just so it’s clear, our position is no PC folders were destroyed.

THE COURT: I understand that. I understand that too.

MR. WEINBERG: All right.

BY MR. DANDAR:

Q Did you understand that Mr. Wollersheim was — did allege that his PC folders were destroyed?

THE COURT: I mean, what are we using —

MR. DANDAR: I’m sorry.

BY MR. DANDAR:

Q Let me ask you this question. This is what I’m leading up to. Mr. Prince, you said that you lied in your deposition in the Yanny vs. RTC case?

A Correct.

Q And you said you sat in this meeting where Mr. Miscavige and Mr. Cooley was at this meeting where a decision was made to destroy evidence of PC folders of Mr. Wollersheim?

A Correct.

Q And Mr. Aznaran is the one who actually went out

Page 1072

to the paper mill and had it pulped?

A Correct.

Q And you did that because you were being loyal to the Church of Scientology?

Q Mr. Prince, are you testifying for the Estate of Lisa McPherson or for me because you’re loyal to the Estate, to the cause, or to Ken Dandar?

A No. I’m testifying because it’s the right thing to do. It’s very difficult to divine truth from — I’m not trying to be vicious here, but it’s very difficult to divine truth from Scientology. People that are currently working on this case, they’ll do anything they can to obstruct it. They’ll do anything they can to make sure —

MR. WEINBERG: Objection, your Honor.

A — that you can’t find out the truth, and —

Page 1073

MR. WEINBERG: He’s going on and on and on.

A — that’s why I do that.

MR. WEINBERG: Objection. He was asked a leading question, Are you testifying because you were loyal to the —

THE COURT: Actually, that wasn’t leading because his answer was no.

MR. WEINBERG: Well, I understand he said no. Now he’s going off into some big explanation.

THE COURT: That’s true. If you want to ask him why are you testifying, then he can go on with his explanation.

BY MR. DANDAR:

Q All right. Why are you testifying in this hearing?

A To give justice and equity a chance — a fair chance, to give all the information, to be able to give the full view of what’s going on. You know, I think it would be fair — it’s only fair that the whole picture is seen.

Q Mr. Prince, Mr. Minton and Stacy Brooks offered to continue to pay you $5,000 a month if you, quote, went down the road with them, close quote, and lied. Isn’t that true?

A I was promised a lot more than that.

Q What else were you promised to lie?

Page 1074

A Retirement.

Q Did they go into any specific details?

A Financial security that will retire me for the rest of my life.

Q Any dollar figures discussed?

A A quarter of a million. That’s normally what Mr. Minton does when he gives people money.

Q Would a quarter of a million be enough?

A For me to retire for the rest of my life? No. I think I’m too young. I would need more. I would have to need more.

Q And is there any doubt in your mind that Mr. Minton and Ms. Brooks proposed this to you, to lie, that they knew that they wanted you to lie?

A Absolutely. They knew they were lying. They knew we all had to lie. I mean, this is the only thing that they felt they could do to end it, disengage, to be done with it. I mean, there’s only so long you can wrestle with this demon.

Q Okay.

THE COURT: And you don’t need, Mr. Weinberg, when it’s your turn, to get up and respond to that. It’s for money, he testified. So I understand where both of you all are coming from here.

MR. WEINBERG: I wasn’t even going to make

Page 1075

that point.

MR. DANDAR: Well —

MR. WEINBERG: One short point on that.

THE COURT: Well, I saw you getting — fuming, and I was thinking, “Oh, dear.”

MR. WEINBERG: I was thinking about all the calls I have to return.

BY MR. DANDAR:

Q Mr. Prince, when you and I met at the mall with Mr. Lirot, Mr. Haverty, and your fiance and you wrote out what’s attached to your declaration, the handwritten note of April 14th, 2002, did I promise you money at all?

A None at all. Money wasn’t even discussed.

Q Did I pay you any money for writing that note?

A Absolutely not.

Q Did I promise to pay you money in the future if you wrote that note?

A No, you did not.

Q And isn’t it true or — what’s the reason why I gave you a retainer of 4,000?

A Because my time is as valuable as anyone else’s.

Q And you’ve been working on this — this hearing preparing documents for me?

A Correct.

THE COURT: You are back now as Mr. Dandar’s

Page 1076

consultant? Is that it?

THE WITNESS: Yes, your Honor.

THE COURT: And expert?

THE WITNESS: Yes, your Honor.

THE COURT: Okay.

BY MR. DANDAR:

Q I certainly haven’t promised you any retirement money, have I?

A No, you have not.

MR. WEINBERG: Your Honor, could we have a direct question instead of a leading question?

THE COURT: Sustained.

BY MR. DANDAR:

Q Now, Mr. Prince, when you were in LMT, did you know that the — and if I asked this, I’ll — I don’t remember asking this — do you know whether or not the LMT received an anonymous $300,000 from Clambake?

MR. WEINBERG: Your Honor, this is beyond the scope. I didn’t ask about it.

THE COURT: It’s beyond the scope. The truth of the matter is, rather than recall, if this is an area that he thinks is important, I’m going to let him get into it.

MR. WEINBERG: All right.

BY MR. DANDAR:

Page 1077

Q Did you know that they got money from Clambake?

A The only — you know, I found out about that —

MR. WEINBERG: Your Honor, could he just answer the question?

THE WITNESS: I’m trying to answer the question.

THE COURT: Counsel, just let it go, would you?

MR. WEINBERG: Okay.

THE COURT: We need to get through this.

MR. WEINBERG: All right.

A I found out about that whole deal with money coming from wherever it came from when Teresa Summers wrote her resignation letter to Stacy Brooks and I read it, where that was mentioned.

THE COURT: So the truth — you did not know about the 300,000, who it came from. Mr. Minton never discussed this with you —

THE WITNESS: Correct, correct.

THE COURT: — is that right?

THE WITNESS: That’s right.

BY MR. DANDAR:

Q And did you ever — while you were with LMT, did you ever hear the phrase “the fat man”?

A No.

Page 1078

Q Okay. Now, with this Key West fishing trip in the summer of 1999, as best I can phrase that, you had already been working for me for a few months, correct?

A Correct.

Q Now, the other people that showed up down in Key West, like Mr. Ford Greene, is that someone that you had ever seen me with before that fishing trip?

A No.

Q Did I go on the fishing trip?

A No, you did not.

Q Did I stay with you and Mr. Leipold and Mr. Greene and Mr. Haverty?

A No.

Q Oh, in that release that’s in evidence, Defendant’s Exhibit No. 231, that release language says that you are conceding or admitting that you were not harmed by the Church of Scientology. Do you have any reason to know why that was put in your release?

A Yes. That was put in the release for the same reason that Scientologists are asked to lie. It’s to protect Scientology at all costs.

Q Now, Mr. Weinberg asked you on cross if you had any personal knowledge of whether or not David Miscavige was physically at the Fort Harrison Hotel while Lisa McPherson was there in November and December of ’95. Do

Page 1079

you remember that?

A Yes.

Q Mr. Prince, would it matter where David Miscavige was physically located as to whether or not he would have knowledge and was personally involved with the care and treatment of Lisa McPherson?

A In my opinion, no.

Q Why not?

A Well, with the state of technology today, it makes no difference whatsoever. But also, based on past experience that I have had with Mr. Miscavige during the Wollersheim case, we were really just a short distance away, and while the hearings were going on, people were calling and reporting all the time. There’s no problem of getting an on-the-ground report immediately in any place in Scientology for Mr. Miscavige.

THE COURT: It is your opinion — I’m sure you’ve probably testified to this, but I can’t remember. I’ve heard from several people. It is your opinion that Mr. Miscavige was kept advised at all times of Lisa McPherson and her situation.

THE WITNESS: Your Honor, it is my opinion that once the situation where she got out of the car and was admitted to the hospital and it became a matter for Office of Special Affairs’ concern, then he

Page 1080

was — he knew about it.

THE COURT: Was it your opinion while she was admittedly PTS-III, undergoing introspection rundown, he would be kept advised of this and the progress?

THE WITNESS: Yes, your Honor.

THE COURT: Or lack of progress?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q Now, Mr. Weinberg asked you to —

THE COURT: And that opinion comes from your having been around him when he was head of RTC?

THE WITNESS: Yes, your Honor.

THE COURT: Or ASI?

THE WITNESS: Both.

THE COURT: Okay.

THE WITNESS: Yes, your Honor.

THE COURT: When Mr. Hubbard was alive and was the head ecclesiastical leader of the Church, would he have been kept advised of PTS Type III introspection rundown?

THE WITNESS: He would have taken it over and dealt with it himself.

THE COURT: My question is, Would he have been kept advised?

Page 1081

THE WITNESS: Yes, your Honor.

THE COURT: Wherever it was being conducted?

THE WITNESS: Well, in all honesty, your Honor, I have to answer this and say that towards the end of Mr. Hubbard’s life —

THE COURT: Forget when folks say he was mad. I understood that.

THE WITNESS: Oh, okay.

THE COURT: When he was in charge of the Church and head ecclesiastical leader, would he have been kept advised of that type of situation, with either a public or staff member of Scientology?

THE WITNESS: Absolutely, your Honor.

THE COURT: Is there any question in your mind whatsoever about that?

THE WITNESS: None whatsoever. He would have taken it over and did it himself.

BY MR. DANDAR:

Q Now, Mr. Weinberg asked you to admit that there’s no written policy in the Church of Scientology to go out and kill somebody, and you said that’s true. Do you recall that?

THE COURT: I’m sorry, what’s that?

BY MR. DANDAR:

Q There’s no written policy in the Church of

Page 1082

Scientology to go and kill somebody.

A Well, there’s one thing that came into evidence here. It was the SP declare of — I think I read down the list. It was maybe eight people. And in that —

THE COURT: I’m sorry, what came into evidence? The, what, SP?

THE WITNESS: Yes, your Honor. It was an SP declare. It was a single sheet of a paper by L. Ron Hubbard declaring — I think it was eight people suppressive persons and declared them fair game. And then on one of the lines, L. Ron Hubbard gave instructions whereby he said any Sea Org member encountering any of the above persons is to use process R245 on them.
Process R245 —

MR. WEINBERG: Your Honor —

THE WITNESS: — is a process —

MR. WEINBERG: — your Honor, objection.

This was the document that was not admitted that Mr. Prince is now testifying about. It was the phony document.

MR. DANDAR: Phony —

MR. WEINBERG: And this is way beyond the scope of my cross-examination.

THE COURT: It’s not beyond the scope because you made it clear there’s absolutely no basis

Page 1083

upon which to make the assertions that he has. Now, if he has a basis, he would be permitted to testify. So it’s not beyond the scope.

MR. WEINBERG: This document that he’s talking about is not in evidence.

THE COURT: All right. If that’s true, then he can’t refer to that document.

MR. DANDAR: Okay. I thought it was.

THE COURT: Well, go find it. Let’s take a break and we’ll see whether it is or not. I couldn’t begin to tell you what documents are in and what ones aren’t. But the clerk would have them, whether they were admitted or not.

MR. DANDAR: Right. Before we take a break, let me ask one more question.

THE COURT: All right.

BY MR. DANDAR:

Q In your tenure at the Church of Scientology, did you ever see anything in writing called R245?

A Yes. It actually comes from a tape lecture. And I forget which tape lecture it was specifically, but it talks about R245 being an effective exteriorization process, whereby the person takes a .45, puts it to his head — a loaded .45, puts it to his head, pulls the trigger, and blows their brains out. That releases the

Page 1084

spirit from the body.

Q Is that a lecture by — who?

A L. Ron Hubbard.

MR. DANDAR: All right. Let’s take our break and let me find that.

THE COURT: All right. It’s 25 after.

We’ll take 15 minutes.

(A break was taken at 10:25 a.m. until approximately 10:55 a.m.)

THE COURT: All right. Where is Mr. Prince?

THE WITNESS: I’m here, your Honor.

THE COURT: You may resume the stand.

You all may be seated.

And, Mr. Dandar, did you find whether that was in or out of evidence?

MR. DANDAR: It was out. And for the clerk’s benefit, I still have it, so make sure I give it back to her. Somewhere. It’s on my table.

Here it is. I have this tendency of walking away with exhibits.

THE COURT: Are we having a light show?

MR. DANDAR: They had a TV or a signal that keeps coming in. We started to watch a soap opera there for a minute.

THE COURT: I see.

Page 1085

MR. DANDAR: But I have a videotape of a Boston picket. And the only reason I want to put this on is because Mr. Weinberg used Mr. Prince picketing in his cross-examination. But this shows what happened before the clip-it, the snippet, that Mr. Weinberg showed.

MR. WEINBERG: Just so it’s clear, this is a different day than the picket that I showed. But he can play it.

THE COURT: All right.

MR. WEINBERG: Ken (motioning to move).

THE WITNESS: It has no audio.

MR. DANDAR: Let’s stop it. Because I did that too.

MR. WEINBERG: Do you know the date of this?

MR. DANDAR: It’s in the beginning of the tape. Just a minute, and I’ll get everything here.

(The tape of the picket was played, entitled “Boston, September 10th, 1998, unedited.”

As noted below, the tape was not reportable and is not transcribed herein.)

THE COURT: Isn’t that pleasant.

MR. DANDAR: Judge, I just put that on to show you it’s not a one-way street.

THE COURT: I understand.

Page 1086

MR. DANDAR: Now, Mr. Prince —

THE COURT: Madam Court Reporter?

THE REPORTER: Yes, ma’am.

THE COURT: If you didn’t get all that, you can put in the record — because this tape can be put in — that it was just a lot of shouting and carrying on and that you did the best you could.

THE REPORTER: Thank you very much, your Honor.

MR. WEINBERG: Are you marking that as an exhibit?

THE COURT: Make a copy of it for the record, because there’s no way the court reporter could be expected to get all that. Talk about your proverbial everybody talking at once.

MR. DANDAR: That would be impossible to write down.

THE COURT: Yes, it would.

So I’m sure you did the best you could, but as far as I’m concerned, it could be basically said you must see the tape because it’s everybody talking at once and loud and obnoxious.

MR. DANDAR: Since Mr. Lirot is bringing in our next witness, I’m going to mark it as 135A because he has all of his exhibits premarked —

Page 1087

THE COURT: All right.

MR. DANDAR: — starting with 136. So the videotape of Boston, September 10th, ’98, is Plaintiff’s 135A.

MR. WEINBERG: Plaintiff’s 135A.

MR. DANDAR: Right.

MR. WEINBERG: It was 9/10?

THE COURT: 9/10/98.

MR. WEINBERG: And you received that into evidence, your Honor?

THE COURT: Yes.

MR. WEINBERG: Thank you.

BY MR. DANDAR:

Q Mr. Prince, the people that were engaging you and Mr. Minton in that picket, where were they from?

A Office of Special Affairs, Boston.

Q Now, Mr. Prince, you talked about the taped lecture series of Mr. Hubbard where he describes R245?

A Correct.

Q And have you seen that?

A I have seen that.

Q Or heard it, whatever it is. I don’t know what it is.

A Yes, I heard it before, read the transcript.

MR. DANDAR: Judge, I have a TV — which I

Page 1088

believe is a TV interview of Mr. Hubbard where he talks about this policy that he wrote called R245.

THE COURT: Well, if this is a lecture of Mr. Hubbard, why, what could be objectionable with Mr. Hubbard —

MR. LIEBERMAN: It’s the characterization of it as a policy.

THE COURT: All right. That will be sustained.

MR. LIEBERMAN: The characterization of what actually was —

MR. DANDAR: I apparently misspoke, I’m sorry. I’ll have Mr. Prince talk about what it is.

As soon as we identify — this is, I believe, Mr. Hubbard speaking, so . . .

THE COURT: What number is it?

MR. DANDAR: Exhibit number? This will be 135B.

THE COURT: Okay.

MR. WEINBERG: Could we just ask the relevance of playing a 1950 speech of L. Ron Hubbard?

Page 1089

MR. DANDAR: If he’s objecting because of the age of the speech, I think it’s quite clear that the age of any document Mr. Hubbard wrote or spoke about has no significance —

MR. WEINBERG: Well —

MR. DANDAR: — in the Church of Scientology. Everything remains the same.

THE COURT: What is it, though? I don’t understand. Is this a —

MR. WEINBERG: This is redirect.

MR. DANDAR: He brought this up on cross.

THE COURT: What did he bring up?

MR. DANDAR: Mr. Weinberg brought up on cross that there’s no written policy of the Church of Scientology about killing somebody.

THE COURT: Okay.

MR. DANDAR: He objected to that Flag order because it wasn’t properly authenticated. That’s fine. It spoke of R245. There’s another publication we’re going to bring in that is current and published by the Church of Scientology that does mention R245.

MR. WEINBERG: What I had asked, just so it’s clear, was there any policy to kill somebody, and he said no. But secondly —

THE COURT: I’m going to allow it, Counsel.

Page 1090

Overruled.

I hope this isn’t terribly long. Is it?

MR. DANDAR: It is. I think it’s 35 minutes.

THE COURT: I’m not going to listen to 35 minutes.

MR. DANDAR: All right. Maybe — what I would like to do over lunch is go down right to the specific area.

MR. LIEBERMAN: Well, your Honor, you see, that’s the problem. I understand your Honor doesn’t want to listen to 35 minutes. You shouldn’t have to listen to 35 minutes. But you cannot take a speech and say this is a religious policy and take two minutes out of an entire lecture about religious matters and then play it and pretend that that gives you any idea as to the context of what’s going on.

THE COURT: All right. I’ll listen to the whole thing.

MR. LIEBERMAN: I don’t want — I’m not urging you.

MR. DANDAR: Let’s do this after lunch. Is that all right?

THE COURT: All right. Let’s do it about 4 o’clock.

Page 1091

MR. DANDAR: Okay.

THE COURT: All right. We’ll do it after lunch.

MR. DANDAR: I hope Mr. Prince is still not on the stand by 4 o’clock. In fact, I think he should be over quite soon.

BY MR. DANDAR:

Q Now, talking about policies of the Church of Scientology, Mr. Prince, are you familiar with the additional steps in evidence, the policy of additional steps of an introspection rundown, where Mr. Hubbard writes that the introspection rundown can be deadly?

A Yes.

Q Are you familiar with search and discovery, the PSSSP course, where it states that some psychotics cannot be kept alive?

A Yes, I am.

Q How do you audit someone who is unconscious?

A Well, I can tell you a process. If a person is laying unconscious on a bed, you simply give them a command, “Give me that hand,” and then you actually execute that command by taking a person’s hand and putting it in your hand. And once you do that, you say, “Thank you.”

And then you put the hand back and say, “Give me that hand.” And you do that repeatedly, over and over.

Page 1092

Q Now, Mr. Weinberg asked you about the Teresita introspection rundown that you participated in — is it Soboba?

A Soboba Indian Reservation.

Q Okay. Is that — was your experience in that introspection rundown similar to what Lisa McPherson experienced?

A I don’t think so.

Q What were the differences?

MR. WEINBERG: Excuse me, your Honor. “What were the differences,” I mean, he doesn’t have any personal knowledge —

THE COURT: No, but I assume as consultant he read all of the depositions of those who did. So I suspect he can testify about that.

MR. WEINBERG: Okay.

THE COURT: Did you read the — did you read the depositions or the statements —

THE WITNESS: Yes, your Honor.

THE COURT: — from the persons who were attending Lisa McPherson?

THE WITNESS: Yes, and I read the notes as well.

MR. WEINBERG: On direct, he already did that. I didn’t ask him to — not — to do anything

Page 1093

different on cross, and now Mr. Dandar is asking him to do the same thing that he did on direct.

THE COURT: I don’t recall this on direct.

Overruled.

MR. WEINBERG: All right.

BY MR. DANDAR:

Q Go ahead. What is the differences? What are the differences?

A The difference being number one that Teresita was a staff member. Mrs. McPherson was a paying Scientology public. Teresita had no intentions of leaving staff or departing from Scientology. Lisa McPherson did.

Beyond that — and, again, there’s so many records. I mean, it’s stated that she was on the introspection rundown. Yet there is no program, there is no evidence, there’s no invoice, there’s no running form, there’s none of those things in evidence that would be in evidence if a person was on an introspection rundown in fact.

And — but as far as the manifestations of wanting to get out of the room that she was locked in, there’s certainly similarities there. But those are some of the differences.

Q When — to your knowledge, your personal knowledge with Teresita, did people talk to Teresita?

Page 1094

A Yes.

Q And — during the entire introspection rundown?

A I mean, no one held long conversations with her. But just basic civility. You know, you walk in a room and you see a person, you say hi. The person says something to you. You either acknowledge or answer the questions. You know, simple things like that.

Q Did you have to assist in any way or did you see others assist in any way Teresita in drinking water?

A Yes.

Q How did they do it?

A Sit down next to her with a glass of water with ice and a straw and sometimes they put — the girls would do it, and I would do it, you know, put your arm around her. Teresita seemed to like that. She was very childlike at times. And hold the straw to her face, and she would drink through the straw. When she would stop, you know, you would tell her: “You just need to drink a little bit more water because it’s good for you. It’s hot out here; it’s the desert. Be a good girl. Drink a little bit more.” And she would drink it.

Q And did you ever see her do that, as time went on in her introspection rundown, where she wouldn’t drink water on her own?

A Yes. But I certainly wouldn’t have any way of

Page 1095

making her drink water if she didn’t want to drink it.

Q Okay. What I’m saying is, did you ever observe her just pick up, without being coached or coaxed, pick up a glass of water or bottled water and just drink it by herself?

A Oh, sure.

Q Was that in the beginning, the middle, or the end, or throughout?

A You know, with Teresita, I don’t think the water was so much an issue because it — at a point in time she wasn’t aware of it, but as she went through introspection and we sat with her and made her drink it, that she came to understand that it was part of the routine, that she had to drink X amount of water every day or, you know, during certain time periods.

Q You said Mr. Hubbard’s doctor, Dr. Denk, came to see her?

A Yes, he did.

Q How many times?

A Once that I know of.

Q And he administered something to her?

A Yes, he did.

Q All right. After he left, did he leave any medicine behind or something for others to administer to her?

Page 1096

A Yes. There were some pills.

Q Do you know what they were?

A I do not. I do not recall what they were.

Q All right.

A But I know they were to make her sleep.

Q Okay. Did he leave instructions with people how often to give that?

A Yes, he did. I think we were to break the tablets in half, to not give her a strong dose, or even lesser amounts and crush it up and mix it in with a protein drink.

Q Do you know of any licensed medical doctor who came in to see Lisa McPherson?

A No, I do not.

Q Do you know if Teresita received a medical examination by a licensed medical doctor before or during — outside of Dr. Denk? Well, let me start — that was a terrible question.

A Yes, he did. He looked in her eyes, looked in her ears, checked her mouth, you know, pressed certain areas of her body to see if it was sore or she would react, check their feet, check their arms, check their back, check their neck.

Page 1097

Q Okay. Was anything else done as far as the medical exam outside of what you just said?

A Not — no, not — I don’t think so.

Q Okay. Now, you mentioned on cross-examination meeting with me and preparing that handwritten note that’s dated April 14th, 2002, the past year, a typed affidavit.

Why did you prepare a handwritten note?

A I felt it was important to preserve in some fashion what I had discussed with you, what had been going on. And since I had plans to investigate it further, in case something happened to me when I went off to see those people that at least there would have been something left written by me that would have indicated something was going on.

Q Now, the day that you prepared that written statement, that was the night you were supposed to meet with Mr. Rinder?

A Correct.

Q Did I assist you at all in preparing that written statement?

A No, you did not.

Q In fact, you purposely went away from me —

MR. WEINBERG: Objection as to the form, your Honor.

THE COURT: Sustained.

Page 1098

BY MR. DANDAR:

Q All right. How close were you to me when you wrote that document?

A I separated myself and went to a different table and did the document.

Q Okay. Now, in that affidavit that you prepared — you typed that all by yourself, correct?

A Correct.

THE COURT: Which affidavit are we talking about?

MR. DANDAR: The —

THE COURT: The last one?

MR. DANDAR: The last one, April 2002, that was actually executed —

THE WITNESS: May 1st.

MR. DANDAR: — May 1st.

THE COURT: What was the date of the last visit with Mr. Minton, Ms. Brooks? What was the date?

MR. DANDAR: What was the date? Was it that Sunday?

THE WITNESS: Yes, it was a Sunday.

THE COURT: The 14th.

MR. DANDAR: The 14th of April.

BY MR. DANDAR:

Q Now, in that affidavit, Mr. Weinberg pointed out

Page 1099

on cross that you put in the wrong date. You put in August of 2001, and Mr. Minton told you on the top of the garage about his last check to me of 500,000?

A Correct.

Q As you sit here today, what are you positive about in reference to that conversation with Mr. Minton?

A Everything that I’ve testified to.

Q When did it take place?

A It took place — you know, I can’t say the exact month, you know. I’m sorry, I wish I could do better with that. But I know it was very warm. I know that specifically it was a $500,000 check.

Q If I told you to assume that Mr. Minton only delivered to me one check for $500,000, was this conversation with Mr. Minton before or after he delivered the check?

A After.

Q And do you have any idea if it was before or after he gave a deposition in May of 2000?

A No, I have no idea.

Q Okay. Now, you mentioned that, when you met with Mr. Minton after he testified before Judge Baird on April 9th, you then telephoned Frank Oliver?

A Correct.

Q To ask Frank Oliver to call me to have me call

Page 1100

you?

A Correct.

Q Why did you go through that circuitous route?

MR. WEINBERG: Objection, because he did —

I asked him the same question, why did you do that, and he explained it.

THE COURT: I think it’s been asked and answered.

BY MR. DANDAR:

Q Okay. Why did you feel your home was bugged?

A Because a person that was hired by Scientology, a private investigator named David Amos, contacted me here in Clearwater, and I went to visit with him in Memphis, Tennessee, and he told me —

MR. WEINBERG: Objection. That’s hearsay, your Honor, whatever — he had some conversation with some guy David Amos.

THE COURT: It’s not introduced as to the truth of the matter asserted. It’s basically as to why he thought his house was bugged, not because it was bugged.

MR. WEINBERG: Well, then he had a conversation. We shouldn’t get into the details of the conversation, should we? Isn’t that just hearsay?

MR. DANDAR: It’s an exception.

Page 1101

THE COURT: I think it’s an exception. One of the exceptions I don’t really understand. I’m going to allow it.

A Mr. David Amos informed me that he had been hired by the Church of Scientology to surveil me, do surveillance on me, and to — what he was looking for, he told me, was that he had been briefed by his Scientology handlers in Los Angeles that Mr. Minton and I were involved in child slavery and we were — had child slaves that we were running around different countries. And Mr. Amos had a street ministry. He’s a very Christian man, and he has a street ministry where he helps abused children.

THE COURT: I don’t need to hear about all that.

THE WITNESS: Okay.

THE COURT: I need to hear why you thought your house was bugged.

A Anyway, he told me that he was specifically hired to bug my house in Chicago, and when I moved from Chicago to Clearwater, that he was hired to do the same there. And he agreed to come out and show me how he did it and where he did it. And I sent him plane tickets and I sent him money to come out to do that. And at the last minute, he got cold feet and didn’t do it. But I did report it to the FBI, the entire incident.

Page 1102

BY MR. DANDAR:

Q Did you go out and visit Mr. Amos?

A Excuse me?

Q Did you actually meet with Mr. Amos?

A Yes, I did.

MR. WEINBERG: Could we get a date of this alleged conversation?

THE COURT: You can when it’s your turn. I don’t care if it’s true. As far as I’m concerned, it’s only why he thought his house was bugged.

MR. WEINBERG: All right. That’s fine.

THE COURT: Which is an explanation as to why he didn’t call from his house, which is all that’s relevant to this.

MR. WEINBERG: But the testimony, of course, is that he did call from the house. He got the call at the house anyway. That’s what he said.

BY MR. DANDAR:

Q Did you go to see Agent Strope of the FDLE before or after you went to Dennis deVlaming’s office?

A After.

Q And did you go to Dennis deVlaming’s office before or after you met me at the mall on April 14th?

MR. WEINBERG: Could he possibly hand it to us, see if we can identify it?

MR. DANDAR: This is a copy of a copy. This is not —

THE COURT: You couldn’t identify it.

MR. WEINBERG: I thought it might be something he had purchased.

Page 1104

THE COURT: No.

MR. DANDAR: No.

MR. WEINBERG: Okay.

THE COURT: I don’t want to leave here at 11:30 if you’ve got 35 minutes of tape you’re going to play. Are you done with Mr. Prince?

MR. DANDAR: Except for this.

THE COURT: All right. Well, put it in. Maybe Mr. Prince will let us know. I mean, I don’t know what Mr. Hubbard —

MR. WEINBERG: Could we just ask — where did Mr. Minton — Dandar get this, is all I’m asking.

MR. DANDAR: This is an interview of Mr. Hubbard from a Granada TV station.

THE COURT: It really doesn’t matter how he got it. He doesn’t ask you how you got your stuff.

MR. WEINBERG: No, no. I thought that this was the original lecture, but this is just a — this is actually just an interview, not the lecture.

MR. DANDAR: This is an interview —

THE COURT: We’ll see what it is, Counselor. Sit down.

MR. WEINBERG: All right. That’s fine.

MR. LIEBERMAN: At the expense of your Honor, I just want to point out that television can’t

Page 1105

possibly be policy letter of the Church of Scientology.

MR. DANDAR: We didn’t say it was a policy letter. It’s a lectured — of a tape lecture of Mr. Hubbard.

And I don’t know where this is taking me now.

MR. LIEBERMAN: It’s not a lecture, you said. It was a television interview.

MR. DANDAR: Well, we’ll see.

THE COURT: Surely you don’t all care if we watch Mr. Hubbard here for 35 minutes, do you? Then I wish you would sit down and let us watch it.

(The tape from Granada television was played as follows.)

THE NARRATOR: Tonight, Well in Action has tracked down one of the most elusive men on earth.

This was the end of our search, an ex-(unintelligible) for Royal Scotland, docked at (unintelligible — Deserta?), a small port in North Africa.

On board about 250 people, may be some sort of a crew, and this mysterious man. (Unintelligible) screen man thought he was a great scientist when (unintelligible). Everybody seems to think he’s a millionaire.

Page 1106

These are no ordinary seamen. Their allegiance and devotion to the mysterious man is total. To them, he is My Commodore. The man is L. Ron Hubbard, charmer, science fiction writer, and showman, the creator of Scientology, and the man who is pushing it into its new, more militant phase. He now requires that his crew must have training in judo and weaponry and must be ethically beyond reproach, tough, formidable, and effective. To them he’s a soldier.

One of them wrote: “That which I have really found is the nearness to the greatness, which is Ron, our founder –”

(The tape was interrupted.)

THE COURT: Stop this for a minute.

(Continuing with tape.)

THE NARRATOR: “– he, above all, My Commodore –”

(The tape was stopped.)

THE COURT: I don’t know what this is, but this is not Mr. Hubbard talking.

MR. PRINCE: There’s a little preamble, if you will, like a little introductory — this is an interviewer talking, and then Mr. Hubbard comes on.

THE COURT: Okay. Go on ahead.

Page 1107

MR. WEINBERG: Well, just so the record is clear, we do object to this, to the comments going in the record of this obviously reporter that was doing — I don’t think he was intending to do a favorable piece back in the ’50s with regard to the Church of Scientology. We object to his comments going into evidence. It’s like Dateline, NBC, or something, it sounds like.

THE COURT: I haven’t heard anything offensive yet.

(The tape was played as follows.)

THE NARRATOR: After several weeks of hunting for him, with the help of almost every radio station along the Mediterranean and beyond, Well in Action at last tracked Hubbard down. Just before dawn on a recent Sunday morning, Hubbard, who finds sleeping difficult, decided at last to speak. He spoke for a long, long time, about his money, his beliefs, his critics, and the new authoritarian structure of Scientology.

But first he spoke about his troubles with the British government. He put on his hat, he smiled, and he began.

MR. HUBBARD: Well, that’s very interesting.

Let’s correct the impression first. You said “you

Page 1108

were in trouble.” Let’s get my relationship to this completely straight. I am the writer of the textbooks of Scientology. About two and a half years ago or so, I even ceased to be a director of organizations.

The government — in the first place, I am not in trouble with the British government, not even faintly. If I went in today or tomorrow through immigration, they would tip their hats and say, “How are you, Mr. Hubbard?” just as they have been doing for years.

THE NARRATOR: The immigration officials might well tip their hats, but they couldn’t let him in. The day we filmed Mr. Hubbard, the home office decided that Britain would be better off without him.

Saint Hill Manor, England, Hubbard’s British headquarters —

(The tape was interrupted.)

THE COURT: Stop, stop.

(Continuing with tape.)

THE NARRATOR: — has made an income of something like one million pounds —

(The tape was stopped.)

THE COURT: This is not whatever you all said it was. This is more this other person than it is Mr. Hubbard. You — find what it is you want

Page 1109

play for me sometime and play it. I don’t want to hear all this other stuff.

MR. DANDAR: All right.

THE COURT: And your objection is sustained as far as this is not relevant. Whoever this is —

MR. DANDAR: That’s it right there? All right.

Go to the beginning of this. All right.

Sorry I had it wrong. Sorry.

(The tape was played as follows.)

THE NARRATOR: . . . simply to a layman what Scientology is.

MR. HUBBARD: I think that would be a relatively easy (unintelligible) because it’s factually a subject which is designed for the layman, and if you couldn’t explain it to a layman, you would have a very difficult time with it.

The subject name means “steel,” which means knowing how in the fullest sense of the word; “ology,” which is “study of.” So it’s actually study of knowingness. That is what the word itself means.

The —

THE NARRATOR: To me —

MR. HUBBARD: Yes.

THE NARRATOR: — to me that doesn’t mean

Page 1110

very much. (Unintelligible.) What does it do for you in theory?

MR. HUBBARD: It increases one’s knowingness. But if a man were totally aware of what was going on around him, he would find it was relatively simple to handle any outnesses in that.

THE NARRATOR: Even after twelve hours of talking, we never got an explanation from him that we could understand. In fact, Scientology is a fake, a religion —

(The tape was stopped.)

THE COURT: This is beyond —

MR. DANDAR: I apologize to the Court. Let me — let me find the spot that I’m trying to get to.

THE COURT: All right.

MR. DANDAR: And if Mr. Weinberg has recross —

THE COURT: Let’s get that done.

MR. DANDAR: I’ll try to get that done.

MR. WEINBERG: I take it the last comment was struck as well. Right?

THE COURT: It certainly was.

MR. WEINBERG: All right.

THE COURT: As a matter of fact, none of this is admissible at this point. I don’t know that

Page 1111

whatever it is they’re trying to find would be admissible.

But you try to find it, Mr. Dandar, over lunch break and we’ll —

MR. DANDAR: Thank you.

THE COURT: — listen to it, and then I’ll see.

MR. DANDAR: All right.

You may cross-examine on the redirect.

MR. WEINBERG: Thank you.

HE COURT: It was very brief.

MR. WEINBERG: Right. Excuse me.

THE WITNESS: You have to turn that thing off, because it keeps getting the radio station.

MR. WEINBERG: I thought you were yelling at me.

THE COURT: No. I thought you were yelling at me.

MR. WEINBERG: I looked up there to see if it was 4 o’clock.

RECROSS-EXAMINATION

BY MR. WEINBERG:

Q Now, you, the first time on redirect, said that Mr. Minton had offered you a lifetime pension to join him, whenever it was, April of 2002. Correct? That’s what you

Page 1112

said?

A Yes.

Q Now — and that typically —

THE COURT: He said “retirement.” I don’t know that if he used the word “pension.”

THE WITNESS: Right.

BY MR. WEINBERG:

Q What you meant was you’re going to be taken care of the rest of your life?

A I meant what I said, which is I would be retired.

Q All right. And that from your experience it was — the people that fell in that category were the people that got the $250,000. Right?

A I gave examples of other people that have — when Mr. Minton has given money to people to last them, this is what it was.

Q Right, like Mr. Dandar in March got the $250,000.

A No. That was for the case.

Q Now — now, you didn’t — do you remember that affidavit, the May 1st affidavit, that you were asked again about?

A Yes.

Q Nowhere in that affidavit do you say that Mr. Pension — Mr. Minton offered you retirement, $250,000,or a lot of money?

Page 1113

A Well, I’m not sure.

Q You didn’t say that in there, yes or no?

A I’m not sure. I would have to look at the thing.

Q Do you want to do that?

A Yes.

MR. WEINBERG: Unfortunately, we had left the documents up there, and they keep getting moved.

THE COURT: This may be it right here. I think I have it still.

THE WITNESS: I could look at that real quick, your Honor.

THE COURT: Do you want to look at my copy?

THE WITNESS: Thank you, your Honor. If you would just give me a moment to scan it.

A No, I don’t see that here. No, I didn’t include that in the declaration.

THE WITNESS: Thank you (handing back to Court).

BY MR. WEINBERG:

Q The truth is, you complained to Stacy Brooks that Mr. Minton had treated you differently and had just nickeled and dimed you over the years. Correct?

A I don’t —

Q Something like that?

A Not quite, no.

Page 1114

Q Well, you were unhappy because you had never been one of the recipients of one of those big $250,000 checks, right?

A I think that — no, that’s incorrect, because the context that we were speaking about is me selling my soul, lying, perjuring myself, lying about Mr. Dandar and whoever else Scientology would want to lie for, because, I mean, you know, they had their shopping list of everything they wanted to be gone. The Wollersheim was one; this was one.

I was supposed to do that. And, you know, I told him: You can’t do that. At no price can you make me turn on people that I have worked with for years for Scientology’s behalf.

And as a matter of fact, I think my statement was I will not help Scientology hurt or destroy one more person.

Q Now, this is a 16-page affidavit, chockful of all kinds of details. You even detailed that Mr. Minton had told you he offered Mr. Wollersheim $200,000 to try to settle that case, right?

A Correct.

Q You put that in there. But you didn’t think it was important to put in this affidavit that Mr. Minton had offered you a retire- — basically enough money so that you could retire? You didn’t think that was important?

A Well, I admit that that is something that’s

Page 1115

important here, but I did not put it there for whatever reason. I mean, you know, I put down what I put down. So if you want to give me a strike for that, okay.

Q All right. Now, you said today that — on redirect that those three resignation letters — remember the March 3rd, ’87, letters, the ones in your hand?

A Correct.

Q Right? You told Mr. Dandar on redirect that you actually executed those letters on March 3rd, 1987, right?

The ones in your hand.

A Yes.

Q And those letters were actually typed up on March 3rd of 1987, right?

A I have no idea when they were typed.

Q Isn’t that what you said on direct?

A No, I didn’t say —

Q Isn’t that what you said on redirect?

A No, I didn’t say who typed it, because I did not type this.

Q No, I didn’t say you typed them up. I said those were actually prepared, the whole letter —

THE COURT: He doesn’t know when they were typed.

MR. WEINBERG: No, that was his testimony.

THE WITNESS: No, it wasn’t.

Page 1116

THE COURT: He said that was what he executed.

BY MR. WEINBERG:

Q What you executed had the date on it already?

A Correct.

Q All right. So — that’s all I’m saying. In other words, the — you didn’t — you aren’t testifying that the — that the resignation letters that you signed were actually — and that, you know, had the date on it were actually prepared a long time before. That’s not what you’re saying?

A No. I made a distinction between the undated resignation that I had signed when I first assumed the position and these ones right here. And I stated why these ones were done, used, instead of the undated ones.

Q Do you remember in your affidavit — and the affidavit we’re talking about is the — that I’m talking about now is the August 1999 affidavit, which is the — the August 20th one, which is the — I call it the murder allegation —

THE COURT: Okay.

BY MR. WEINBERG:

Q — affidavit.

MR. WEINBERG: If I can approach —

THE COURT: You may.

Page 1117

MR. WEINBERG: — is probably the easiest way of doing this.

BY MR. WEINBERG:

Q Do you remember that in paragraph 14 of — this is the — just so you see it, is your August 20th, 1999.

A M’hum (affirmative).

Q You see, just read paragraph 14 down to — it’s short.

A Okay.

Q Read it to yourself.

A Okay.

Q Have you seen that?

A Yes.

Q Now, what you say in this affidavit in paragraph 14 on page 6 is: “I was forcefully removed,” which is, you’ve already testified, on March 3rd. Then you say, quote: “It is my belief that my undated resignation which I signed when I was appointed to the board was then dated and used to make it appear that I had resigned when I had not.”

So the testimony that you swore to in this affidavit that all that was — that all that happened was — that what happened was that a date was put on something that you had previously signed is absolutely contrary to what you just testified in this court.

Page 1118

Correct?

A What — what I wrote there, I wrote that as my belief. I didn’t recall this, but once it was shown to me and recalled to me, I testified about it. I’m not able to recall every little thing all the time. That was my belief at the time. But then when you showed me this, I remembered more about the incident that happened in 1986.

Q ’87.

A ’87, sorry, January of ’87.

Q So you were wrong in your August 20th, 1999, sworn affidavit?

A Right. In that — in that regard, in that particular regard.

MR. WEINBERG: Now, do you have — can I ask the clerk for a document, your Honor?

THE COURT: You may.

MR. WEINBERG: Plaintiff’s 15B.

I’m going to show him 15B, which is Teresa Summers’ letter.

THE COURT: For the record, you probably ought to say what you said to me.

I don’t know, did you get that, Madam Court Reporter?

THE REPORTER: Yes, ma’am, I did.

MR. WEINBERG: I guess I was speaking louder

Page 1119

than I thought.

BY MR. WEINBERG:

Q All right. I’m showing you the September 7th, 2001, Teresa Summers letter. And I believe you said on redirect that you had learned about the Clambake money and the issues with regard to the Clambake money in — for the first time — or issues with regard to LMT money for the first time in Teresa Summers’ letter, right?

A Correct.

Q And this is Teresa Summers’ letter?

A Yes, it is.

Q Now, can you look at page 1 of that letter.

A Yes.

Q Paragraph 1.

A Where it says, “Please be advised”?

Q I’m sorry, where it says –subparagraph 1. Do you see where the No. 1 —

A Yes.

Q Where it says, “The revelation –” This is a letter to Stacy Brooks from Teresa Summers, right?

A Correct.

Q “The revelation in your recent deposition that 800,000 was donated to the LMT from foreign sources and that every penny of that money was delivered to Bob Minton is very difficult to make sense of. For at least the last

Page 1120

six months, I have been told by you” all of the LMT funding — I’ve been told by you that all of the LMT funding came from Bob Minton.”

Do you see that?

A Yes, I do.

Q And that’s what you were told as well, correct, that all of the LMT funding came from Bob Minton?

A No, that’s not what I was told.

Q Now, let me — will you turn to the next-to-last page, please. The last paragraph of the next-to-last page, the one that says “in addition”?

A Yes.

Q Do you see that? Summers says: “In addition, Bob and Jesse were involved with bringing money into the country illegally, and you have never discussed this matter with me.”

A Yes.

Q Do you know what she’s talking about?

A No. And she doesn’t either. I never brought any money into the country illegally.

Q And Ms. Summers is someone that’s worked at the LMT?

A Correct. I can tell you what Ms. Summers is referring to, if you’d like to know.

THE COURT: It doesn’t matter.

Page 1121

THE WITNESS: Okay.

MR. WEINBERG: Doesn’t matter.

THE COURT: I have no idea why he bothered to bring that out. Maybe he wanted you to look bad or something.

THE WITNESS: Well . . .

BY MR. WEINBERG:

Q All right. Now, finally, you testified on redirect that the — you testified about the release that you executed with Mr. Rathbun at the end of October, the beginning of November, 1992. Do you remember that testimony?

A In November of 1992, I was not in the Sea Org. I was in Minneapolis, Minnesota.

Q What I’m asking you is, Do you recall on redirect you testified about the release that you executed at the time that you left the Church of Scientology?

A Correct.

Q All right. And your testimony is that you were under duress when you did that. Correct?

A Absolutely, yes.

Q And you executed it in a meeting — in a meeting with Mr. Rathbun, right?

A Correct.

Q Just you and Mr. Rathbun?

Page 1122

A No. There were other staff there.

Q Do you remember who else was there?

A I believe Mr. Sutter was there.

Q They were sitting — you were sitting in a meeting with him?

A If I say he’s there, that means that I can see him. That means we’re in the same room or something like that, you know?

Q So you’re saying he was there?

A Correct.

Q Okay. Well, let me show you two — and then it’s your testimony that, at the end, Mr. Rathbun made you put the wrong date on the release. Right? That was your testimony?

A It was convenient for them to have it as November, as opposed to October. I don’t know why. That’s what I —

Q But it was his origination, not yours?

A Correct.

Q Okay. I’m going to play you a short clip from the beginning of this meeting with Mr. Rathbun and then the end of the meeting with Mr. Rathbun.

A You know, I resent that unless you show the whole thing.

THE COURT: I think that’s fair. If you’re

Page 1123

going to show something and suggest whether he was or wasn’t under duress, you have to play the whole meeting.

MR. WEINBERG: It’s a long meeting. When I have is the clip, and, you know, we can provide the whole thing if you want it. But what I intend to do on this redirect is to show him the beginning of the meeting, which would indicate he was in the meeting, and the end of the meeting where he signs the —

MR. RATHBUN: Okay. This is Marty Rathbun with Jesse Prince. And Jesse is going out of the Sea Org, and he agreed to have a —

(The playback was interrupted.)

THE COURT: Where is Jesse Prince?

MR. WEINBERG: He’s at the front.

(Continuing with tape.)

MR. RATHBUN: — knowledge that he might have about outstanding —

(The playback was stopped.)

MR. DANDAR: Does Mr. Prince know he’s being videotaped?

Page 1124

THE WITNESS: No.

BY MR. WEINBERG:

Q Well, you knew the meeting was recorded. A Not videotaped. And this is the first time I’ve seen this, and this is really gross. This is from a hidden camera.

Q Did you know it was being recorded or not?

A On tape. A tape recording was running, not a video.

Q Is this you?

A Yes, it is. I think it is.

THE COURT: Doesn’t look — I’m sorry, it doesn’t look like him.

THE WITNESS: Let me see. They’re full of tricks.

MR. DANDAR: Yes, why don’t you see.

THE WITNESS: I can’t tell.

MR. WEINBERG: Well, when you hear your voice, I think you can tell.

THE COURT: It does not look like Mr. Prince to me.

THE WITNESS: You know, I really resent this. This is secret. Taping this is exactly what I’ve been saying here. This is exactly what they do, the illegal surveillance. It’s just sneaky all the

Page 1125

time.

MR. WEINBERG: I asked him the question, Did you know you were being recorded?

THE COURT: He said no.

MR. WEINBERG: The answer is yes. I think he said yes.

THE COURT: He knew there was a tape recorder playing. He did not know he was being videotaped.

MR. WEINBERG: I guess the question, your Honor, is once you know that —

THE COURT: Quite frankly, I would resent the tar out of it. I hope there’s none of that going on ever. If you’re going to ever take a picture of me, you’d better tell me, because I would resent the tar out of it, to say nothing of the fact that I’m not certain it’s legal.

So whatever it is, Mr. Prince, you didn’t know anything about this?

THE WITNESS: No, your Honor. They did not have my permission to do this.

THE COURT: All right.

THE WITNESS: This is from a hidden, secret camera.

THE COURT: Go ahead and play it. We’ll

Page 1126

decide whether or not it’s legal or not.

(The playback continued.)

MR. RATHBUN: — cases going on or other matters that are involved, illegal or whatever.

MR. PRINCE: That’s right (unintelligible).

MR. RATHBUN: We’re here alone?

MR. PRINCE: That’s right.

MR. RATHBUN: Nobody else here?

MR. PRINCE: No coercion, nobody doing anything.

MR. RATHBUN: Okay. And you’re here of your own free will?

MR. PRINCE: That’s right.

MR. RATHBUN: There’s no — nobody is holding anything over your head?

MR. PRINCE: Yes.

MR. RATHBUN: There’s no threat?

MR. PRINCE: No threat, no pressure. I know exactly what I’m doing. I’m not sitting here (unintelligible) worrying about legal counsel knowing what the hell is going on. I know exactly what I’m doing in a professional capacity.

MR. RATHBUN: Great. Okay. The first thing we’re going to do was you’ve reviewed a couple of outstanding complaints, which were the RICO case,

Page 1127

which is our —

(The playback was interrupted.)

THE WITNESS: You know, I can’t hardly stand this. I can hardly stand this.

MR. WEINBERG: I was going to play the end of it.

THE COURT: Well, how in the world can you play something that suggested somebody wasn’t under coercion and not play it? How do I know —

MR. WEINBERG: If we can — we can play the whole —

THE COURT: This is the RICO case? What is your purpose in playing it?

MR. WEINBERG: Mr. Prince — Mr. Prince said that there were all kinds of people in the room, that he was being coerced, that it was forced. And there are no people.

THE WITNESS: They left the room.

MR. WEINBERG: Excuse me.

THE WITNESS: They had left the room. This was totally staged, to protect the Church, as I’ve given testimony before: Mr. Prince, this is what you need to do to leave our compound.

So I’m sitting here doing whatever they asked me to do to leave their compound. There’s been

Page 1128

articles in George magazine, press — Riverside Press, and my suit about the coercion. So, you know, and now you’re showing me a secret camera thing? I resent this highly. I really resent this.

MR. DANDAR: We object. And for the record, that sure doesn’t look like Mr. Prince.

MR. WEINBERG: Well, you know that’s you.

You’ve heard you.

THE WITNESS: Look, I resent this because it was done — not only did everybody leave the room —

THE COURT: You mean there were others there before this started?

THE WITNESS: Yes. Absolutely. They were all standing around in that room. And then it’s like, “Okay, now, let’s get this extra protection in.”

Signing a release for your client wasn’t enough. Signing a release saying that they didn’t harm me or damage me wasn’t enough for them. Now they’ve got to sit down and do this. You know? I really think anybody with common sense knows what’s going on here.

BY MR. WEINBERG:

Q When did you sign it? The beginning of the meeting or the end of the meeting?

A What, the release?

Page 1129

Q Yes.

A Probably at the end. I mean, they wanted me to — this is what I had to do to leave. I had been locked up —

THE WITNESS: Your Honor, I had to escape from Scientology. They didn’t even know where I went.

THE COURT: I don’t want to hear it anymore.

If he didn’t know about it, I don’t want to see it.

MR. WEINBERG: All right. That’s all my questions.

THE COURT: As far as I’m concerned, it can be stricken.

MR. WEINBERG: Those are all my questions.

THE COURT: All right.

FURTHER REDIRECT EXAMINATION

BY MR. DANDAR:

Q Mr. Prince, do you have that affidavit that’s —

THE COURT: And I might suggest in the future, if you’re going to videotape parishioners, that they be told about it. Quite frankly, that is not very churchly, to be candid.

MR. LIEBERMAN: Well, your Honor, just to be clear, it is the Church’s position that Mr. Prince absolutely knew this was being taped and the videotape introductory section of this before the interview

Page 1130

starts shows them setting up electronic equipment.

And it’s his testimony here that he didn’t know about it. That is not — we do not go along with that. I want the record to reflect that.

THE COURT: It’s very odd that someone leaving a Church has to be videotaped.

The truth is, it’s very odd he would have to sign a release. I mean, it’s all very odd.

However, it’s just my suggestion to you so that you don’t ever have to listen to somebody again that you might just want to put it in your release, “I understand that I’m being videotaped as I sign this.”

Then you won’t have to worry about it. I won’t have to hear somebody saying that he resents you taking my picture, for whatever reason.

THE WITNESS: Your Honor, this comes from —

THE COURT: I don’t want to hear any more about it.

THE WITNESS: Okay.

THE COURT: Go on ahead.

BY MR. DANDAR:

Q Mr. Prince, I want to direct your attention to paragraph —

THE COURT: I didn’t have to sign a release when I left my church, quite frankly. I left, I went

Page 1131

back, who cared?

BY MR. DANDAR:

Q Paragraph 15 of your —

THE COURT: Nobody ever sued me either. I never testified against them.

BY MR. DANDAR:

Q Paragraph 15 of your April 2002 affidavit, paragraph 15 — I don’t have the page numbers on my copy for some strange reason. But the second page of paragraph 15, could you please read the highlighted portion on — beginning —

THE COURT: Which affidavit is this now?

MR. DANDAR: The April 2002.

THE WITNESS: May 1st.

THE COURT: Okay.

A “Bob told me that I was the one making a big mistake, that if I walked down this road with them, they would hire an attorney for me and everything would be okay. Both he and Stacy Brooks told me of a new life, where we would all live in happiness and prosperity.”

BY MR. DANDAR:

Q What were the details of living a new life in happiness and prosperity?

A Retired, vacationing on the Islands regularly, running around the world, world travel.

Page 1132

Q When you — did the —

THE COURT: What paragraph was that?

MR. DANDAR: It was paragraph 15. If I had the exhibit, I could give you the page number.

THE COURT: It’s all right, paragraph 15.

MR. DANDAR: It’s the second page of paragraph 15. It’s a real long paragraph. It’s lines 19 through 22.

THE COURT: All right.

MR. DANDAR: And this wasn’t part of the recross of Mr. Weinberg, so if it’s objected to, I understand. But —

MR. WEINBERG: Well, I’ll object in advance.

BY MR. DANDAR:

Q Mr. Prince, when Teresita went insane or psychotic, did she do it like Lisa did, in the middle of the street, in public, or somewhere else?

A She did it — she was at a work station — oh, god, we were in a big time crunch. We were making the first —

THE COURT: We really don’t care about that. Was it out in public or at work?

THE WITNESS: No, it was at work.

BY MR. DANDAR:

Q So there was no public PR flap?

Page 1133

A Correct.

MR. DANDAR: And outside of wanting to play this videotape, that’s all the questions I have.

THE COURT: Okay. Anything further?

Thank you, sir.

THE WITNESS: Thank you, your Honor.

THE COURT: Your testimony is finished. You may step down.

I don’t know about that videotape either. I have no idea what that is either. So you find whatever it is you want to find, show it to counsel in advance, see what it is, and see if we can make some context out of it and see if it has any relevance.

MR. DANDAR: All right.

THE COURT: All right. Now, it’s noontime.

It’s 12:05. We’ll be in recess until 1:15.

MR. WEINBERG: How about 1:30?

THE COURT: No, 1:15.

MR. WEINBERG: Or 1 o’clock?

THE COURT: No, 1:15.

MR. WEINBERG: 1:15, all right.

(A lunch recess was taken at 12:08 p.m.)

_______________________________

Page 1134

STATE OF FLORIDA

COUNTY OF PINELLAS

I, Debra S. (Laughbaum) Turner, Registered Diplomate Reporter, certify that I was authorized to and did stenographically report the foregoing proceedings and that the transcript is a true record.

WITNESS MY HAND this 11th day of July, 2002, at St. Petersburg, Pinellas County, Florida.

Q Mr. Prince, what I was trying to do before the lunch break was finish up on the meetings that you had with Mr. Minton and Stacy Brooks.

A Okay.

Q I believe we left off with your meeting with them when things got a little testy at the hotel for dinner.

A At the Radisson.

Q At the Radisson. In my — your note attached to your affidavit, you said you met with me before you met with them that Sunday. So that was April 14th.

A Okay.

Q All right? So let’s go from then on. What happened after April 14th?

587

A Mmm —

THE COURT: I’m sorry, he met with you before he met with them?

MR. DANDAR: That same day. That is where this handwritten note —

THE COURT: Right. For some reason, I thought it was after. But it was before?

MR. DANDAR: On this particular day he met with me at the mall with Mr. Lirot. And that was April 14th.

THE COURT: In the afternoon? Then he went there in the evening?

MR. DANDAR: Then he went there.

BY MR. DANDAR:

Q What happened after April 14th?

A Mmm, well, contact again — and I think I mentioned I had the one phone conversation with Mr. Minton where I invited him over to my house.

But they — they talked to me — or got messages to me via my fiancee. They would talk to her.

And if anything happened — we wouldn’t talk, we were not talking.

Q And what messages did you receive from Mr. Minton and Ms. Brooks that way?

MR. WEINBERG: Objection. Hearsay, your Honor.

THE COURT: Hearsay. That would have to be

588

hearsay. I mean, that would have nothing to do with Mr. Minton’s state of mind or anything in this proceeding, so you would have to, at the very least, bring in the other person.

BY MR. DANDAR:

Q So you never talked with Mr. Minton or Ms. Brooks since then directly, one-on-one?

A I talked with Mrs. Brooks. Mmm, she just told me that everything was going to be fine, regardless of whether or not I agreed to go with them or participate in activities with them with Scientology. She just told me things were
going to be okay.

Q When did Ms. Brooks stop paying you your monthly income?

A Either March or April.

Q And you said before that you went to Denis deVlaming’s office and spoke with him, and he couldn’t help you because of the conflict of interest. Did you go to any law enforcement?

A Well, it’s not entirely true to say that Mr. DeVlaming couldn’t help me.

What Mr. DeVlaming did do is refer me to his brother because, again, I wanted to somehow get a federal law enforcement involved in this, since my perception was that the criminal activity — conspiracy and criminal activity happened at least in New

589

York, New Hampshire and Clearwater.

Mmm, he said that he would talk with a federal agent that he did know and get back with me. He — I guess maybe a day or so later, he had a conversation with the federal agent, Mr. Douglas DeVlaming.

And he told me, after speaking with an agent, they thought that it would make a difficult case because Mr. Minton was now on the stand lying, telling lies. If he changed his mind —

MR. WEINBERG: Objection. Hearsay, your Honor.

THE COURT: Sustained.

BY MR. DANDAR:

Q Did you ever meet personally with law enforcement?

A Yes, I did.

Q All right. Who did you meet with?

A I met with FDLE Agent Lee Strope.

Q Did you talk about Mr. Minton and Ms. Brooks?

A I pretty much gave Mr. Strope a complete rundown of the meetings, with the dates similar to how I laid it out there in the affidavit. And after —

THE COURT: Mr. Strope is with what agency?

THE WITNESS: FDLE.

THE COURT: FDLE?

A And after speaking with him, he asked me to give Bob Minton a message. And the message was that if it is determined that you have perjured yourself on the stand,

590

that he would see to it that charges would be brought.

BY MR. DANDAR:

Q This is Mr. Strope telling you to talk to Mr. Minton?

A This is a message Mr. Strope asked me to give Mr. Minton specifically.

Q Did you give him that message?

A Mmm, I wrote — I hand-wrote what he said. I gave it to my fiancee and she read it to Mr. Minton over the phone.

Q Okay.

THE COURT: Mr. Prince, is it your testimony here today under oath an agent of the Florida Department of Law Enforcement asked you to deliver a message to someone?

THE WITNESS: Yes, your Honor.

BY MR. DANDAR:

Q Any other meetings with law enforcement?

A Not about this specific incident.

Q Okay. Now, what was your impression, after meeting with Ms. Brooks and Mr. Minton, on the meetings you have just mentioned, all of these meetings —

MR. WEINBERG: Objection to the form. What was his impression?

THE COURT: Yes. What does that mean?

591

MR. DANDAR: I didn’t finish my sentence.

THE COURT: Go ahead.

BY MR. DANDAR:

Q What was your impression as to who was the person who was creating the scenario that I told Mr. Minton to lie?

A Mr. Rinder.

Q And what is the basis of that? What is the basis of your impression it is Mr. Rinder?

A Because that is what they said.

Q Who said?

A Bob and Stacy.

Q All right.

MR. WEINBERG: Well, could we just — I mean, is that — your Honor, so his testimony is that at some point Bob Minton and Stacy Brooks said that Mike Rinder said for Mr. Minton to lie?

THE COURT: Yes. That is his testimony.

MR. WEINBERG: Could we date that testimony, please?

THE COURT: Mr. Prince, is that your testimony?

THE WITNESS: Yes, it is.

THE COURT: If you could look at your affidavit and tell us which one of these conversations that that conversation took place.

THE WITNESS: Okay. Let me see if I see it

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here. I don’t seem to have my affidavit up here.

THE COURT: You don’t? I think I have it right here, if it will help.

MR. DANDAR: Well, I have the affidavit right here. I’m sorry. I was looking at it instead of listening to the Court.

THE WITNESS: This would have had to have happened sometime after the date that I mentioned on Page 5, Line 16, Paragraph Number 11 of the 3rd of April or 2nd of April, sometime after that time period.

BY MR. DANDAR:

Q After this — after the 2nd or 3rd of April?

A Correct.

Q All right. Did Mr. Minton or Ms. Brooks tell you this on more than one occasion?

A Well, the subject of the meetings — after they returned to Clearwater with Mr. Bunker April 2nd, the many times that I met with them, the subject of the conversations concerned what they were asked — or what they were being asked to do, what they wanted me to do.

So that was a continuing theme until, you know, the point that it finally broke off, because I didn’t, I guess, qualify to meet with the Scientologists or speak with them about this myself. But it was a continuing theme of

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conversations.

THE COURT: I believe that, in fairness, Mr. Prince may have testified to some of this yesterday, too.

MR. DANDAR: I think so maybe.

THE COURT: And may have dated some of this yesterday. I’m looking through his affidavit. I am remembering some of his testimony from yesterday.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Now, Mr. Prince, yesterday you talked about Volume 0 and 00. Do you recall that? You looked in the book Introduction To Ethics and you said —

A Yes.

Q — what you were looking for may be in Volume 0 and 00?

A Yes.

Q And there are a bunch of books over there. Are there any of the books you want to refer the Court to?

A Sure, if I could just walk over there.

MR. DANDAR: Is that all right, Judge?

THE COURT: Yes. By the way, Ms. Greenway asked if she could take my picture. You can’t take pictures when court is in session. So I gave her permission to come in and take pictures when court

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wasn’t in session of whatever she wanted to take pictures for. But when court is in session you cannot take pictures unless you are connected with the media and you are a pool photographer. Then you can.

BY MR. DANDAR:

Q No other books?

A No.

Q All right.

A This is — first off, I would like to say yesterday that I said that this was a crime for a person to give testimony about Scientology. I actually misspoke. It is a suppressive act to do that, according to this document here, suppressive acts, suppression of Scientology, Scientologists, the fair game law. And what it states specifically is —

THE WITNESS: Yes, your Honor. It is 553, what I’m going to make reference to.

MR. LIEBERMAN: Could we have the date on that book?

BY MR. DANDAR:

Q Copyright on the front?

THE COURT: Would it matter with these policies —

MR. LIEBERMAN: Well, some, it may.

THE WITNESS: This is copyright 1970 through — what is it, 1950, it looks like. These are all of the copyright notices here.

THE COURT: Okay. I’m going to let you-all take a look at it.

MR. WEINBERG: Now? Or —

THE COURT: No. Let him go ahead and have his testimony, and then before cross-examination you-all can look at the book.

BY MR. DANDAR:

Q So a suppressive act is someone saying they want to leave Scientology?

A Yes. And testifying as a hostile witness against Scientology in public is a suppressive act.

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Q All right. That has to do with testifying?

A Correct.

Q What about leaving Scientology or saying you want to leave?

A Mmm, yesterday I showed the reference and we went through that. It’s a high crime to publicly depart Scientology.

Q This may be something I already marked. Let me show you what has been marked as Plaintiff’s Exhibit 133. CS Series 22.

Can you identify that Exhibit 133?

A Yes. This is an HCO bulletin of 28 November, 1970, Mmm, subtitled “CS Series 22.” The “CS Series” means case supervisor series. It’s — it’s a series that is a staple or basic for persons that are supervising auditing in Scientology. And this document refers to the subject of psychosis.

Q And this document came from the PTS/SP course book you read yesterday. Is that correct?

A Correct.

Q Okay. Now —

THE COURT: Who is permitted to take that course? Maybe you asked it before, but, I mean, if I’m a new Scientologist, new public member, can I go register for that course?

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THE WITNESS: You certainly could. Any Scientologist in good standing —

THE COURT: Could take that course?

THE WITNESS: Yes, your Honor.

THE COURT: Okay.

BY MR. DANDAR:

Q This course book also contains the search and discovery bulletin?

A I believe it does.

Q Okay. Now, this particular document, Exhibit 133, CS Series 22, does this have anything to do with people wanting to leave?

A Well, if you turn to the second page, it talks about the easiest ways for a case supervisor to detect the insane, and we go down here to Number 6, it says: “They often seek transfers or wish to leave.”

Q Now, does this apply to staff as well as public members?

A Absolutely.

THE COURT: I think this is already in evidence, isn’t it?

MR. DANDAR: I’m not sure. You told me to mark this yesterday as an exhibit.

THE COURT: Well, now that I’m looking at it, I’m thinking I read it before. But if you are not

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sure, you want to introduce it again, why, that is all right.

MR. DANDAR: I’m really not sure.

THE COURT: All right.

MR. DANDAR: I know we talked about this yesterday.

THE COURT: I’m not positive if this was the document, but I have read some of this before.

MR. DANDAR: Yes. It is quite possible.

MR. WEINBERG: We have no problem, but the next-to-last sentence says: “The insane can be helped, they are not hopeless.” We don’t have a problem with this. But the introspection rundown comes after this policy.

THE COURT: But you have no objection to this being introduced?

MR. WEINBERG: No.

MR. DANDAR: We move it into evidence.

MR. WEINBERG: It was referred to in the introspection rundown which was introduced three or four years later, this policy.

THE COURT: All right.

BY MR. DANDAR:

Q Speaking of the introspection rundown, Mr. Prince, speaking of your experience, expertise, is there any part of

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the introspection rundown that is considered religious?

MR. WEINBERG: Objection to his competence to this because Mr. Prince previously testified he wasn’t trained on the introspection rundown and never — as an auditor never did any introspection rundown.

THE COURT: I thought he did.

THE WITNESS: That is correct. I did. I never was — I never stated that I was not trained on the introspection rundown.

THE COURT: I’m sorry, what?

THE WITNESS: I never stated I was not trained on the introspection rundown. That is false. I am very trained on the introspection rundown.

MR. WEINBERG: What he said was he participated in an isolation watch, not as the auditor, you know, but as one of the people staying with Teresita.

THE COURT: Is isolation watch and introspection rundown the same?

MR. WEINBERG: It is part, Step whatever it is, 0, 00.

THE COURT: All right.

MR. DANDAR: This will kind of answer the question, I think.

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BY MR. DANDAR:

Q So, Mr. Prince, is there parts or all of the introspection rundown that is religious? A religious practice?

A Mmm, in the very first bulletin about the introspection rundown, L. Ron Hubbard describes it as a new technical breakthrough that marveled something else of the 20th century, I forget specifically what it says there. But it was hailed as a researched scientific discovery for handling insanity.

MR. WEINBERG: So, your Honor, is what Mr. Dandar is doing is challenging whether or not the introspection rundown is part of the religion of Scientology? Because if he is, I think that has already been decided in this case and it is not appropriate and we should not be wasting our time on it.

THE COURT: Haven’t we decided that — or — I don’t know because I don’t know — I saw a motion once that dealt with religiocity. I didn’t hear any of that.

MR. DANDAR: That was not the —

MR. LIEBERMAN: But you have stated several times, your Honor, that there is no question in this case as to the religious nature of Scientology or

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religious nature of the introspection rundown.

THE COURT: Okay. I know I have stated that I have no question on the — that the Church of Scientology is a religion and it is a recognized religion in the Church. And I have no question in my mind that Lisa McPherson was undergoing some sort of introspection rundown. I didn’t know whether I said that introspection rundown is part of the religion of the Church. I don’t even know if that is a call for me to make, to tell you the truth. I would suspect the Church doctrine would tell us whether it is or isn’t.

MR. LIEBERMAN: That is correct. And the Church characterizes what is religious practice.

THE COURT: I don’t know if I have seen that or not. I know we have a Mr. Rice affidavit. I haven’t looked at it in some time.

MR. LIEBERMAN: And he quite clearly places it within the Scientology practice. In fact, every part of Scientology, by definition, is part of Scientology belief and practice and is not a matter for the Court to challenge what is characterized by the Church as this religion.

THE COURT: I am going to let him answer this. I think he already has answered it, but I don’t know

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we’re going to go there. And certainly one answer isn’t going to get it there.

MR. DANDAR: Right.

BY MR. DANDAR:

Q Mr. Prince, Mr. Hubbard called it scientific breakthrough?

A That is correct.

Q Did he ever call it religious practice?

A Never.

Q Did he call auditing a religious practice?

A No.

Q Oh.

A Not to my knowledge. I mean, this whole business of religion — I don’t know, you know, it is kind of — has kind of reared its head in Scientology every now and again. When I was here at the Flag Service Organization in 1979, there was a scare — a cold war scare of some nuclear threat and conscription in the Army and on and on. This is what we were told. So all of the staff had to do a two-week course called the minister’s course where you are instantly trained to be a minister. This was part of — a program which, in part, was to kind of improve or create a religious image for Scientology.

But if you will notice, in every document that Mr. Hubbard writes about Scientology, whether or not it is a

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green —

THE COURT: I don’t want to hear this. The United States Government, State of Florida, on and on down, determined Scientology is a religion, the Church of Scientology is a church. I don’t care what they used to think, what they used to say. It doesn’t matter. That is it.

MR. DANDAR: What I’m — I was getting at is just the introspection rundown itself.

THE COURT: Okay.

BY MR. DANDAR:

Q The part of the introspection rundown talking about get some rest —

MR. WEINBERG: Your Honor, could I —

BY MR. DANDAR:

Q — make sure you eat —

MR. WEINBERG: This is precisely why Mr. Prince should not be an expert, considered an expert in Scientology, because as he sits here today, he still is sitting there saying it is not even a religion or a church. He doesn’t recognize it —

THE COURT: He wasn’t. He was talking about some things that were said back in the 1970s when they were all sitting around talking —

MR. WEINBERG: He just said that — well, I

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don’t want to argue with you. I mean, it — that is where he was going with this and that is what this — that is what this is about.

MR. DANDAR: It is not what this is about. I just asked him what I’m asking him now, the introspection rundown, the part that talks about resting and eating — resting and eating, something else —

THE COURT: 0, 00.

MR. DANDAR: Yes, those two steps.

BY MR. DANDAR:

Q In your experience within the Church of Scientology, was that ever considered a spiritual or religious part of Scientology?

MR. LIEBERMAN: Your Honor, again, this is unconstitutional inquiry. You can’t bifurcate a religious practice and say part is and part isn’t. To just even hear this testimony is an unconstitutional attack on the religion.

THE COURT: Mr. Lieberman, your objection on that is preserved.

MR. LIEBERMAN: Thank you.

A Well, you know, since — you know, people that are atheists or other ideas also rest and sleep. You know, it never came to me that this was a religious experience to

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rest and eat.

BY MR. DANDAR:

Q Well, and in your knowledge of Scientology, if someone is injected with Valium or chloral hydrate, are they eligible to have auditing?

A According to — Mmm — the HCO bulletin entitled Model Session —

Q How do you spell that?

A Model, M-O-D-E-L, model session, a person who has had drugs or who has used drugs continuously is not eligible for auditing until six weeks after the period of taking the drugs.

Q Now, in your experience with Teresita, you said Dr. Dink, Hubbard’s doctor, came out and injected her with some kind of drug?

A Correct.

Q And she went to sleep?

A Correct.

Q How soon after that did she have auditing?

A Within hours after awaking.

Q Was that within the written policy?

A Is that what now? I’m sorry.

Q Is that per policy to have an auditing right after you have slept off the effects of the drug?

A Well, in the introspection rundown bulletin, it

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states that each program is tailored specifically for the individual. So to that degree, if the person had to sleep first in order to get auditing, they would get the auditing, but then there is also later references in Scientology technology which state that in a period after the auditing that was delivered, while the person was on drugs, you could then go back and check those areas again to make sure that everything is fine.

Q Okay. Let me show you Exhibit 134. And do you recognize where this copy of this Page 258 comes from?

A Yes. This comes from the Hubbard Administrative Dictionary.

Q And what — how does it define the phrase “high crimes”?

A It says: “High crimes. 1. These consist of publicly departing Scientology or committing suppressive acts. Cancellation of certificates, classifications and awards and becoming fair game are amongst the penalties which can be leveled for this type of offense as well as those recommended by Committees of Evidence.”

MR. DANDAR: Okay. That is all of the questions I have.

THE COURT: All right. Thank you. You may inquire.

MR. WEINBERG: Thank you.

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CROSS-EXAMINATION BY MR. WEINBERG:

Q Mr. Prince, David Miscavige busted you from your position of authority — your executive position of authority in the RTC — in March of 1987, didn’t he?

A Correct.

THE COURT: I’m sorry, you just got started.

Did you want to introduce this 134?

MR. DANDAR: Yes, sir. In fact —

MR. WEINBERG: We object to that. I would like to see the dictionary, see what the date of the dictionary was.

MR. DANDAR: Do you have it here? In fact, I just realized, unless you want to do this later, there are a bunch of things I marked and didn’t move them into evidence.

THE COURT: I’ll go ahead and let you do that —

MR. DANDAR: Later?

THE COURT: — later. But don’t forget.

MR. DANDAR: Right. Yes.

MR. WEINBERG: Should I start over?

THE COURT: Yes.

BY MR. WEINBERG:

Q Mr. Prince, David Miscavige busted you from your

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position — your executive position of authority in the RTC in March of 1987, didn’t he?

A Correct.

Q And at that time you were removed from your post, the last executive post you ever held in the Church of Scientology. Correct?

A Correct.

Q And that post, you said, was deputy inspector general external. Right?

A Right.

Q Now, you were removed because you had supported Pat Broeker and Annie Broeker and Vicki Aznaran in their effort to change Scientology tech. Correct?

A That is categorically false.

Q That was precisely what occurred, that Pat Broeker, who had designated himself the loyal officer, was in the process of changing, among other things, the Scientology grade chart, right? That is what he was doing?

A That is categorically false.

Q So Mr. Broeker wasn’t doing that?

A Correct.

Q And you never acknowledged that Mr. Broeker did that?

A Correct.

Q So Mr. Broeker wasn’t off on his own, trying to

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change the religion of Scientology, after Mr. Hubbard died?

A Well —

Q Yes? Or no?

A Excuse me. Let me answer the question.

THE COURT: Well, I’ll tell you how this works on cross-examination. Go ahead and answer the question, but if you feel you have to explain your answer, you are allowed to do that after you have answered it.

A In other words, I was not there — let me — I was not there. I didn’t see him changing anything. And, again, I was going to say, I have heard some hearsay about it. Since you vehemently object about it, I won’t comment about it, but I — you know, I haven’t personally been with Mr. Broeker when he’s altering Scientology technology.

Q When you were in the RTC prior to March of 1987, in that year after Mr. Hubbard died, you became aware of the

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fact that some point in time that Mr. Broeker was changing and altering Scientology tech, weren’t you?

A Incorrect.

Q You became aware of the fact that Vicki Aznaran was part of an effort to change Scientology tech, weren’t you?

A Absolutely incorrect.

Q And what happened in March of 1987 is that Mr. Broeker was removed from all authority. Correct?

A Mr. Broeker was removed from authority.

THE COURT: Wasn’t? Or was?

THE WITNESS: He was, your Honor.

BY MR. WEINBERG:

Q Annie Broeker, his wife, was removed from all positions of authority. Correct?

A To my knowledge, that is correct.

Q Your boss, Vicki Aznaran, was removed from her position of authority. Correct?

A Correct.

Q And you were removed?

A Correct.

Q And you were at that time — at that point in time, you went from what you described as an executive position with some authority in the — in RTC. Right?

A Correct.

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Q To no authority whatsoever?

A No. That is incorrect.

Q From — for the next five years after March of 1987, did you ever hold a position where someone was junior to you? You know what I mean by that?

A Yes, I do. And, yes, I have.

Q I mean, you were, what, a machine operator after that?

A Mmm, no. I worked on post-production, pre-production and post-production for films.

Q That was one of the things you did, and you were a Cinemix, was that your job?

A No.

Q What was your job?

A My job was like an assistant engineer, assistant sound mixer. Again, I state I worked for post-production and pre-production for films and videos.

Q During that period of time you were in the RPF a couple of times. Correct?

A Incorrect.

Q How many times were you in the RPF?

A I was in the RPF two times, but not that period of time.

Q You were in the RPF in March of 1987. Correct?

A Correct.

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Q All right. Until what, the end of 1987?

A Mmm, I think it was — I wasn’t in there a very long time. I think maybe four months.

Q By the way, there is no higher crime in Scientology than changing the tech. Correct?

A That is incorrect.

Q Well, what would be a higher crime than changing Mr. Hubbard’s scriptures?

A Placing Scientology and Scientologists at risk.

Q One of the highest crimes in Scientology is to alter the tech. Correct?

A It is a high crime to do that. Yes.

Q Now, for the next — for those five years after you were busted — and that was the day you claimed, by the way, that you pulled these guns on David Miscavige and threatened to kill him?

A You didn’t mention a specific day. What day are you talking about?

Q Well, what day are you talking about when you were busted?

THE COURT: Without worrying too much about the date, the date you testified about when you were rousted from bed or got out of bed and went and got the guns, that is on the same day, right?

THE WITNESS: Yes. I’m sorry.

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THE COURT: That is the day you were busted?

THE WITNESS: Yes.

THE COURT: That is what he was referring to.

THE WITNESS: Okay. I’m sorry. I just didn’t understand the question.

BY MR. WEINBERG:

Q That is the same day you claim you pulled these guns on David Miscavige and you threatened to kill him.

Correct?

A I didn’t threaten to kill Mr. Miscavige. What — maybe you have a wrong idea about what happened there.

I came there to defend myself. Twelve people were attacking me, were trying to hold me. Because I do know karate and have a black belt in it, I was able to get them away from me until I went and got protection for myself.

Q So then these twelve people that were attacking you let you go back to your room, get these two loaded guns?

A They didn’t know where I was going.

Q That didn’t really happen, did it, Mr. Prince?

A Yes, it did.

Q You didn’t pull guns on David Miscavige.

A Yes, it did.

Q So this is the person you say you could still be friendly with?

A You know, Mmm — yes. And I need to explain

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something here because, you know, Mr. Weinberg, you and I have been around and around on this in front of Judge Moody. So, you know, you are giving me the exact same questions and I’ll sit here and be patient with you, but I think the record reflects we have done this one or two times before.

THE COURT: See, I haven’t heard it. This is my hearing, so we’ll do it again.

MR. DANDAR: Explain yourself.

THE WITNESS: Okay.

BY MR. WEINBERG:

Q So you contend that you really did go back to your room, get two loaded weapons, and walk back and enter a room and point them directly at David Miscavige?

A No, I never walked back into a room. By that time —

Q You ran back into the room?

A Would you like me to explain it? I —

Q Explain it.

MR. DANDAR: Wait. Wait. Objection.

BY MR. WEINBERG:

Q Did you —

MR. DANDAR: He needs to explain it.

Mr. Weinberg —

MR. WEINBERG: I’ll withdraw that question.

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BY MR. WEINBERG:

Q Did you point two loaded guns —

MR. DANDAR: That is not fair.

BY MR. WEINBERG:

Q — at David Miscavige?

A No, I did not.

Q Who did you point them at?

A I had the one gun on my hip and the .45 in my hand. And they stood this way. The assault rifle never was pointed at anyone. It was just on my hip like this. And I had the .45.

And Mr. Miscavige, when he saw me, walked directly up to me with those guns in my hand and said, “Jesse, we are friends. Let’s talk.”

So I don’t think he felt that threatened. And I think that Judge Moody pointed that out to you the last time we were doing this.

Q I mean, no one would feel threatened when they had just busted somebody from position and the person got so mad to go back to the room and get two loaded guns and walk into a room. You can’t imagine anybody would be threatened by that, would they?

A I think that is a mischaracterization of what happened.

Q Well, my question is was there a particular reason

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why you never told that story until — until you started getting paid to be a witness in the FACTNet case in 19 — whatever it is, 1998?

Why you waited all those years to tell that story?

A Mmm, I don’t know how to answer that question, Mr. Weinberg. You are associating things that don’t associate. You are associating with me being paid telling stories. And there is no association there.

Q Well, is there a particular reason, in the years after this alleged incident took place, that took you until 1998 to first tell this story about pulling guns on David Miscavige?

MR. DANDAR: Object to the form. It makes no sense. Telling stories where? Under oath? In a deposition? To his friends?

THE COURT: I don’t, either, because I don’t know whether you are talking about the first time he ever testified about that, and if that is the first case he was ever involved in, that is the first time he ever testified about that.

MR. WEINBERG: I —

THE COURT: I’ll tell you one thing —

MR. WEINBERG: I’m sorry, I didn’t mean to —

THE COURT: — don’t get ahead of me because you want to go at this witness.

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MR. WEINBERG: You are right.

THE COURT: I won’t have it.

MR. WEINBERG: Right.

THE COURT: I won’t have you really cutting this man off. I mean, I know you want to get where you want to go. But you’ll have to go slow.

And, Mr. Prince, whatever you told Judge Moody, I haven’t heard it, I haven’t seen too much of the transcript before Judge Moody, so I don’t want to hear what I — I already told Judge Moody this, I am not Judge Moody.

THE WITNESS: I understand.

THE COURT: If he asks you a question, unless I tell him, “You can’t ask that question,” just answer, even if you have already answered it before.

Okay?

THE WITNESS: Okay. Yes, your Honor.

THE COURT: Let’s go.

BY MR. WEINBERG:

Q You were interviewed by Earle Cooley while still in the Church in 1988, weren’t you, in relation to another lawsuit?

A I would have to see something about that. I’m not sure what you are talking about.

Q You didn’t say anything about the guns to him, did

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you?

A Again, I would have to see what you’re talking about.

Q Well, you mention the 1994 interview with Mr. Cooley. You didn’t say anything about the guns to him in that interview, did you?

A I mean, you know, you are mixing apples and oranges. I mean, I don’t understand what you are asking me. I mean, I have told that story long before 1998 to my friends, my family, people that I know. I mean, you know, it isn’t like here is some money, let’s tell this story. I beg to differ with the way you are characterizing what happened here.

Q The reason you told the story to Mr. Minton in April of this year was to threaten him as to what you would do as to what kind of person you were? I mean, what did you tell him about it for?

A I told him that story, as I gave testimony yesterday, to show that Scientology, more than likely, will never keep or honor an agreement with anyone. It wasn’t to say I’m going to run and shoot you with guns. It was to give him an example to show him that Scientology will never honor an agreement.

Q Now, you would agree that the positions that you held after you were busted were extremely low positions in

619

the Church of Scientology?

A I would beg to differ on that, as well.

Q Now, you were — you were so humiliated, apparently, by Mr. — what you claim Mr. Miscavige did in March of 1987 that you pulled these guns on him. That is what it was about, wasn’t it?

A Absolutely not. And even as we have been sitting here, I think I made it clear to you why I went and got those guns. It wasn’t humiliation. It was being attacked.

Q You were —

A Physically attacked.

Q You resented the fact that you had been busted?

A I resented the fact I was being physically attacked by people that used to be my friends.

Q No. My question is did you resent the fact that you had been busted from your executive position in RTC?

A And I’ll answer the question it isn’t so much that I resented the fact that —

THE COURT: Come on, Mr. Prince, of course you must have been annoyed. I don’t know why we’re playing a semantics game. Anybody would be annoyed if they were busted from the position they thought —

THE WITNESS: No, your Honor, that isn’t right.

I think that deserves clarification because I was

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pretty much tired of that activity that I had been involved in, in Scientology. I was ready for a change. I was ready to be done with that position because that — that position responsibility entailed being involved in criminal activity.

This is something that I had not experienced in Scientology prior to going to Gilman, Hot Springs and working at that level. To me, Scientology was something different than what I was doing.

So, no, it wasn’t a big deal for me, you know. I was already wanting to be away from that responsibility.

But what was a big problem for me was twelve people grabbing me, because I had an earlier incident of that happening in Scientology where six people grabbed me and locked me in a room for three months, and I ended up staying 16 years. So that had precedent over that position I was being removed from.

BY MR. WEINBERG:

Q So you were relieved by the fact you were busted from your position?

A I would not say that that is true. I have no vehement dislike for him. I dislike the things that he does. But I don’t envy his position. He’s the leader of a religion. He has a lot of responsibility. That doesn’t give you license to be a criminal, though.

Q You spent the last four years, ever since you met apparently sometime in the summer of 1998, started getting paid by, ever since you met Mr. Minton, you spent the last four years trying to destroy David Miscavige, haven’t you?

A That is incorrect.

Q You have picketed where you have spoken vilely and obscenely about Mr. Miscavige, haven’t you?

A Yes, I have.

Q You have picketed various Churches of Scientology around the country and even in the world, correct?

A That is incorrect. I never picketed an organization outside of the United States.

Q Just in this country?

A Correct.

Q You have threatened David Miscavige in these pickets, haven’t you?

A I need you to clarify what you mean by threatened for me, please.

Q Threatened to do harm to him.

A I have jokingly alluded to it, yes, I have.

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Q You thought it was funny?

A Yes, I did.

Q And did you think it was funny when you were outside the various Churches of Scientology, including what you call the mecca of Scientology, holding signs and shouting obscenities about the leader? You thought that was funny, too?

A I — I think you would have to show me or present evidence that I was holding a sign, shouting obscenities.

Q Oh, we will, Mr. Prince.

A Okay. I would like to see that.

Q Did you think that was funny?

A I would like to see the evidence, please, sir.

Q Would you consider, sir — I mean, I think you said that Mr. Minton was the — something basically the most harassed person you’d ever seen, something to that order?

A Something along that order, correct.

Q Would you consider what you and Mr. Minton and Ms. Greenway and Mr. Alexander and Mr. Oliver and the other folks at the LMT — would you consider what you were doing harassing Scientology?

A Well, what were we doing that was supposed to be harassing?

Q I mean —

THE COURT: His question to you is whatever it

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was you were doing, would that be, in your mind, harassing Scientology?

THE WITNESS: Well, I guess to clarify it, if it meant picketing, does that mean harassing Scientology? It has a broader meaning to me. It means I’m exercising my First Amendment rights as a citizen to protest.

Mmm, if you want to call that harassing Scientology, I call it exercising my freedom.

BY MR. WEINBERG:

Q I’m asking you, because remember you talked about the harassment time line of Mr. Minton?

A Yes.

Q Do you remember talking about that?

A Yes.

Q And my question to you, if — if we put all of your pickets and all Mr. Minton’s pickets and all your postings and all Mr. Minton’s postings and all of the postings of these folks that have been in and out of the LMT and all the pickets of them on a time line, do you think that time line might be somewhat larger than this Minton harassment time line?

A I think it would be minuscule and it would pale by comparison.

Q By the way, are you part of an anti-Scientology

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movement?

A I have never been part of an anti-Scientology movement.

Q Are you an anti-Scientologist?

A No, I am not.

Q What do you consider yourself?

A I consider myself in the instant case where I’m sitting right here today an expert witness concerning Scientology.

Prior to that, I worked in an establishment whereby I helped people who had been victimized by Scientology.

Q And would you consider Mr. Minton to be an anti-Scientologist during those four years that you were part of the A team, I think you said?

A I consider Mr. Minton to be an activist.

Q An activist?

A Yes.

Q What is that?

A You tell me what it is. Do you need to know what the word means? I mean, he was an —

Q What do you mean —

A — activist concerning —

Q What do you mean when you say he was an activist?

A He was an activist ensuring the rights, basic

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human rights, that are accorded to us through our constitution.

I think Mr. Minton got started on his relationship with Scientology when he found out a Scientologist was trying to remove the name “Scientology” from a newsgroup — or at least this is the way he explained it to me. And how
lawyers and raids and things would come to even discuss Scientology, which is how I knew it from being in Scientology.

I knew if you ever spoke about Scientology outside of Scientology, you would get clobbered. So to actually see people doing it openly on the Internet was —

THE COURT: That is well past the answer. You don’t have to — we have to try to get through this.

THE WITNESS: Okay.

THE COURT: He simply asked you to define what an activist was. And I think you have done that.

THE WITNESS: All right.

BY MR. WEINBERG:

Q Now, when did you begin — when did you begin your work against Scientology? What date or time?

A Mmm, I began to give testimony concerning Scientology, to the best of my recollection, in the FACTNet case.

Q Specifically, up until I — I think you said you

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considered yourself a Scientologist until, I think you said, 1997. Correct? Isn’t that what you said in your testimony?

A I think maybe ’96, I said.

Q All right. So you considered yourself a Scientologist after you left the Church of Scientology in 1992, after you say that you were — you said all those horrible things happened to you in the five-year period, you still considered yourself a Scientologist in ’93, ’94, ’95 and ’96. Correct?

A I think I should clarify that for you, if that is okay. I think that I still had Scientology values. I think that I still respected some of the tenets of Scientology, and I freely associated with Scientologists.

Q Well, you were working for a public member of Scientology for several years, right?

A Several years is incorrect.

Q How many years?

A Maybe one.

Q This is the job that the Church had helped you get after you left the Church where you were making $60,000 or $70,000 a year. Was that your testimony?

A I think you are mis-characterizing what happened. No, that is not my testimony. The Church didn’t help me do anything. It never has.

Q Well, just tell us one of those Scientology values

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that you — that you continue to accept and feel close to after you left the Church of Scientology.

A That man — man is a spiritual entity. That — Mmm — man is capable of seemingly — seemingly more capable than is realized and those potentials can be cultivated and used and expanded on.

Q Any other ones?

A You know, some of the organical principles about the importance of organization, the importance of schedules. You know, these kind of things.

Q When you were a Scientologist, you believed, did you not, that psychiatric problems were spiritual in nature. Correct? That is what you believed? And could be dealt with spiritually through the religion of Scientology. You believed that when you were a Scientologist, didn’t you?

A Yes, I did.

Q And that is what Scientologists believe, don’t they?

A I can’t speak for all Scientologists. I know that, you know, as you are trained in Scientology, you accept more and more of what you read, and it’s a progression, it is a degradation of belief system, I guess.

But I couldn’t say that everyone believes that.

Q Well, you could say that Scientologists — no Scientologist would want to be committed to a mental

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institution. You can say that, can’t you, from your years as a Scientologist?

A Mr. Weinberg, I can say that about Scientologists and anyone else. There is no one that I know that is aching to be committed to an institution.

Q But I’m asking you from when you were a Scientologist —

A Uh-huh?

Q — the last thing that you would have — you would have rather shot yourself than be committed to a mental institution?

A Absolutely not. I mean, that is unreasonable. It is irrational.

Q Well, can you think of anything worse, as a Scientologist, than to be committed to a mental institution?

Can you just answer that question?

A Rehabilitation Project Force, maybe.

Q One of the fundamental principles of the Church is — is the Church’s abhorrence with psychiatry and mental health treatment. Correct?

A Well, you know, Mr. Weinberg —

Q Can you just answer that question?

A I used to believe that is the answer. I used to believe that. But I found, from Mr. Hubbard’s autopsy report that I had a copy of, that he himself was taking

629

psychiatric medication —

MR. WEINBERG: Objection. Move to strike.

A — in his life. So maybe —

THE COURT: Stop. There is an objection. You have to stop.

MR. WEINBERG: It is not responsive to the question. It was a very simple question. Yes or no.

MR. DANDAR: I would say this is outside of the scope of direct and the issues.

THE COURT: It is not outside the scope of direct and not outside the scope of the issues but, quite frankly, this is not helping me any.

MR. WEINBERG: All right.

THE COURT: It is an interesting banter between you and Mr. Prince and —

MR. WEINBERG: I’ll go on.

THE COURT: — this might be of interest to a jury, but it really isn’t of interest —

MR. WEINBERG: All right.

THE COURT: — to me.

BY MR. WEINBERG:

Q Since you have met Bob Minton, all of the money that you have received since June, other than this apparently $4,000 that you just got from Mr. Dandar, that

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you have received since June, July, of 1998, up until April of 2002, came directly or indirectly from Mr. Minton, didn’t it?

A That is incorrect.

Q And all of the money — all of the money that you have received in that period of time you received as a result of your work about or against or involving Scientology?

A That is incorrect.

Q Correct?

A That is incorrect.

Q What is incorrect about that statement?

A I think that — Mmm — that all of the money that I have had during those periods of time derived from those activities, that is — specifically is incorrect about it.

Q What, 99 percent of it? 95 percent of it?

A You know, I have turned over my financial records to you. I think they speak for themselves.

Q All right. Let me play you — because you asked me to — let me play you a video — some videos and maybe this will refresh your recollection. I’ll ask you some questions about it.

A All right.

MR. WEINBERG: Get the first one.

MR. DANDAR: We’re going to object. If he

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plays the video that they would like to play from the Boston picket, I demand that they play the whole video so that you, Judge, can see what Mr. Prince was responding to in that very vile video that you may have already seen.

You only saw their version of it. There is like two, three, four minutes of extremely vile language coming from ministers of the Church of Scientology to bull bait Mr. Prince into responding the way he did on video. So if they are
going to do that, they need to play the whole thing.

MR. WEINBERG: That is not the one I’m playing, first of all —

THE COURT: All right.

MR. WEINBERG: — to make it easy. Secondly, if he wants to do something later, he can.

THE COURT: There is a rule of completeness which we’ll get into when we get to trial. At a trial, if somebody will try to pick and choose, I’m probably going to insist on the rule of completeness in an appropriate case.

But in this hearing, if they play something and you think I need to see it all, make a little note, tell them to keep it there and play the whole thing on redirect.

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MR. DANDAR: All right.

THE COURT: Or ask them if they’ll play it all.

If they say no, then you play it.

MR. DANDAR: All right.

MR. WEINBERG: Now, this is a video in front of the Ft. Harrison on November 30, 1998.

______________________________________

(WHEREUPON, the video was played.)

“You want to see the other side of the sign, too? Just want to make sure you get all of the information, all of the data.

“Tell David I’m coming with a dick so big, I’m gonna knock his goddamn spine out cuz I’m black. I got a big dick. I’m black. I got a big dick.

“Hey. Hey. Didn’t that guy have curly hair? (Inaudible.)

“No. No. Jesse. Yo momma. I been fucking your momma a long time (inaudible). That’s why you got that curly hair.”

(End of playing of the video tape.)

______________________________________

BY MR. WEINBERG:

Q Do you recognize yourself, Mr.~Prince?

A Yes, I do.

Q You recognize Mr. Minton?

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A Yes, I do.

Q And you thought that was funny? Your statement about Mr. Miscavige?

A Yes, I did.

Q You don’t consider that a threat?

A No, I don’t.

Q You think it is appropriate for an expert, or anybody, for that matter, but particularly an expert on — supposedly on religion to be in front of the Ft. Harrison to be making obscene statements about David Miscavige like that to other — to Scientologists?

A You know, I think there was an indiscretion that happened there, certainly.

Q And you consider it harassment for you and Mr. Prince — and Mr. Minton and others to be holding signs like the one you were holding, “Lisa, blood on her hands,”and the one Mr. Minton was holding about the Third Reich, do you consider that harassment to be walking in front of the mecca of Scientology? Do you consider that to be harassment?

MR. WEINBERG: This is on the same day in front of the Criminal Court Complex.

BY MR. WEINBERG:

Q Now, do you remember this being the day of the arraignment in the criminal case and do you remember being in front of the complex with Stacy Brooks, Bob Minton, Ken Dandar, Dr. Garko and yourself? Do you remember that photo?

A I remember that photo.

Q And do you recognize that as the criminal complex in Clearwater?

A The one on 49th Street?

Q Yes.

A Yes, I do.

Q And who took that photo?

A You know, I’m not sure.

Q And do you think that is funny? “Scientology, Hubbard Third Reich,” do you think that is funny?

A You know, I think those people in that picture are exercising their constitutional rights.

Q Do you think it is appropriate for the trial team of Mr. Dandar, Dr. Garko and you and Ms. Brooks, along with

635

Mr. Minton, to be standing in front of a public building holding signs like that?

MR. DANDAR: Objection.

BY MR. WEINBERG:

Q Do you think that is appropriate?

MR. DANDAR: Objection. Mr. Minton is not part of any trial team.

THE COURT: He said “and Mr. Minton.” So I’m assuming he was excluding him.

MR. WEINBERG: That is what I did.

BY MR. WEINBERG:

Q Do you consider that to be appropriate behavior?

A I consider that unless I’m committing a crime, I’m exercising my constitutional rights as an American citizen.

Q Do you believe that that constitutes harassment of the Church of Scientology?

A No, I don’t. I think if I was doing anything illegal, Scientology would have had me arrested on the spot.

Q Okay.

THE COURT: Harassment is not illegal. I guess what he’s trying to ask you is, in addition to exercising your First Amendment rights, did you consider that that might be considered harassment?

THE WITNESS: You know, and I — my answer again is no. My answer is I’m exercising my

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constitutional rights as an American citizen.

BY MR. WEINBERG:

Q You wouldn’t consider that picket —

MR. WEINBERG: Can you put that photo back up?

BY MR. WEINBERG:

Q Somebody asked you — I think Mr. Dandar asked you whether or not he was ever on a picket.

THE COURT: Now, Counselor, in all fairness, that is a picture, that is not a picket. What we saw before —

MR. WEINBERG: I understand. I was asking to ask him. This is a picture.

BY MR. WEINBERG:

Q My question is what was going on with these signs in front of the Clearwater courthouse? What were you-all doing with these signs?

A I think we had been picketing earlier.

THE COURT: Was Mr. Dandar with you when you were picketing?

THE WITNESS: Absolutely not. Neither was Mr. Garko.

BY MR. WEINBERG:

Q And whose idea was it to pose for this picture?

A I don’t know. I don’t recall. I don’t remember.

Q I mean, no one forced you-all to do this.

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Correct?

A Correct.

MR. WEINBERG: Go to the next one, please.
______________________________________

(WHEREUPON, the video was played.)

“You work for a criminal organization. And they’re going to be found out. You take that and put it on the camera and run it to Miscavige, your leader, your guru. He’s going down.”

(End of playing of video tape.)

______________________________________

BY MR. WEINBERG:

Q Now, that was right outside the Clearwater Bank building where all the people go in to eat. Correct?

A Yes. It was.

Q And right down the street, as you look down the street, is where the LMT offices were?

A That is correct.

Q All right. And do you consider that to be a threat to Mr. Miscavige where you say he’s going down?

A No, I do not. And I think I have to — you know, because this is just a little snippet you are showing here, I think I should give the situation that was occurring.

On that very street that you saw me in front of where the Lisa McPherson Trust is around the corner, on that

638

particular day I had gone to a shop on Cleveland to buy a pack of cigarettes and go back to the office.

From the moment I walked out of my office, all of the way up to the door of the shop I went to and all of the way back, a Scientology OSA person had a camera on me like this (indicating).

I was annoyed. If that is a crime, find me guilty.

Q Now, was that your purpose when you say, “You’re going down,” was your purpose to get rid of Mr. Miscavige from being the chairman of the board or the ecclesiastical leader of Scientology?

A My purpose was to express my annoyance.

Q And “guru,” were you just being funny?

A Again, my purpose was to express my annoyance.

Q Now, was that your agenda? Strike that.

Was it Mr. Minton’s agenda — was part of his agenda to get rid of David Miscavige?

A You had Mr. Minton up here —

Q I’m just asking you.

A — Mr. Weinberg, forever, you know.

Q I’m asking you.

A He never said that to me. He never said that to me.

THE COURT: There is an answer in the

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courtroom. It is called “I don’t know.” If it is —

A He never — no, he never said that to me.

BY MR. WEINBERG:

Q Now, you described you, Ms. Brooks and Mr. Minton as the A team, right?

A Correct.

Q And the A team got formed in the summer of 1998?

A I would say — Mmm — thereabouts.

Q Right. And the A team continued to be —

A Maybe — wait a minute. I misspoke about that because that A team business didn’t come up until after — after we’d worked together for a while and had done things.

And that concept came out — in the summer of ’98 is when I first met them, so I think it would be a misrepresentation to say that the A team was in the summer of ’98, at least to my best recollection as I sit here today.

Q So when was it?

A And I can’t be sure. It was sometime later.

Q When you said it became the A team after you had done things, what kind of things? Are you talking about like — do you mean like pickets and sending postings and things like that? Are those the things that you were doing?

A I think more like helping people directly.

Q Helping people?

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A Yes.

Q How was Mr. Minton helping people, by standing and holding signs like that?

A Well, you know, I guess there is a myriad of answers for that. But what I meant to say, helping people, I meant helping people that had run into problems with Scientology and were not able to resolve them so that they can get on with their lives.

Q Now, where did the A team concept come from?

A You know, I think there used to be a television program.

Q Are you talking about the one with Mr. T?

A If you let me finish. You know, the reason why I can’t answer that question, because when those television series were going on, I was in the Sea Org and we weren’t allowed to watch TV. So I have a big missing section in my life with serial programs and things like that.

So again I’ll say there was some program that had the A team on it. And I think Mr. Minton brought it up and — but —

Q And —

A — but I have never seen a program called the A team or anything like that.

Q When you said the A team yesterday, what did you mean, A team? What was it that the A team was doing?

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A The A team was myself, Bob and Stacy. And the A team were helping people that needed help to resolve issues with Scientology.

You know, just to — to show how far at the other end of the spectrums were, Mr. Minton actually thought he was helping Scientology by helping these people resolve issues with Scientology.

Q Do you remember speaking to the media about bringing Mr. Miscavige down?

A No. I do not.

MR. WEINBERG: Play that next one, please.
______________________________________

(WHEREUPON, the video was played.)

“It takes standing up and recognizing it for what it is, a dead, arcane idea. We’re dealing with people who are ignorant and we’re going to bring them down.”

BY MR. WEINBERG:

Q Do you remember that?

A I object to that very — I can’t object, but that was an obvious edit where you sliced two things together.

And I think you are mis-characterizing a speech that I gave for a vigil for Lisa McPherson where the press was there. I was not speaking for the press. I was speaking to former Scientologists.

642

Q Were you talking about bringing down Scientology?

Is that what you were talking about?

MR. DANDAR: We object and ask the whole thing be played.

THE COURT: I think that is fair.

MR. WEINBERG: It was a newscast, we didn’t — we can play the whole newscast. It takes a minute.

THE COURT: I don’t want the whole newscast.

Just whatever Mr. Prince said.

MR. WEINBERG: Well, that is what Mr. Prince said. That is all he said is what we just played.

THE COURT: Well, it did look like there was a definite splice.

MR. WEINBERG: There was. One of these newscasts where the reporter said something and Stacy Brooks said something and he said the first thing on there, Mr. Prince, then somebody else said something, then he said the last thing.

We took the two things Mr. Prince said and put it together. But we can play the whole section.

THE COURT: It makes it look like he said all that together, and it may not have been.

I think if what it is you are trying to do is every time he said we’re going to bring him down, what is it you mean when you say that?

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THE WITNESS: Expose — expose what is actually going on.

THE COURT: Okay.

THE WITNESS: You know, expose the fact that private investigators are being used to terrorize citizens because they disagree with Scientology.

Expose the fact that someone gave $100,000, and it is Scientology’s policy, if you don’t use a service that you paid for, they will refund it to you.

THE COURT: Normally, when you want to say we’re going to expose somebody, you don’t say expose somebody, you say bring them down, that kind of means put them out of business. That is what I mean by that. What did you mean by it?

THE WITNESS: I mean ending the criminal activity. Ending the assault of citizens who have no way to protect themselves once they get on the bad side of Scientology.

THE COURT: When you say “We are going to bring you down,” this is your testimony, you did not mean put the Church of Scientology out of business, do away with the Church?

THE WITNESS: Right, in the illegal activities. I never had a — as I said, corrupt activities wasn’t even anything in my mind during the majority

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of my stay in Scientology. These are things that I learned about after I got to Gilman, Hot Springs, and started working directly for Mr. Hubbard and Mr. Miscavige. I was an ignorant, blind person to it prior to that time.

BY MR. WEINBERG:

Q When you said in that newscast that I just played, quote, “It takes standing up and recognizing it for what it is, a dead, arcane idea,” that was how you — that — you were expressing your opinion about Scientology, that is what
you meant by that, isn’t it?

A No. You have taken this out of context because I don’t know what “It is.” You showed me a little snippet. I don’t know what you’re talking about.

THE COURT: I don’t, either.

MR. WEINBERG: I have the transcript. We’ll play the whole tape because we are obviously not going to get done today.

BY MR. WEINBERG:

Q But — it was a response to a question, “Today they spoke out against the Church of Scientology,” and then they play what you said about it. But we’ll play the whole thing. It takes about a minute. All right.

You remember going on several trips to Europe with Mr. Minton, correct?

645

A I think I went on a couple of trips with Mr. Minton.

Q All right. He paid for the trips?

A Correct.

Q Who else went with you?

A You know, as a matter of fact, I only traveled to Europe with Mr. Minton one time.

Q And the purpose of that trip was?

A To visit with his business partner, Jeff Schmidt, to have a face-to-face with him to find out specifically what Scientology-hired private investigator David Lee was doing to try to get him to a — do a similar thing as Bob and Stacy, basically turn against Bob and provide criminal information so Scientology could use it to attack Bob Minton.

Q Now, do you remember being in Germany with Mr. Minton and Ms. Brooks in or about June of 2000?

A I think I was in Leipzig, Germany.

Q And Mr. Minton paid for that trip?

A I think that trip was paid by the Lisa McPherson Trust.

Q So in June of 2000 you were on the payroll of the Lisa McPherson Trust at that point?

A Correct.

Q You had just gone on the payroll?

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A You know, I can’t remember.

Q And do you remember — you remember being in the DB lounge?

THE COURT: What is that?

A Yes.

THE COURT: What is a DB lounge?

MR. WEINBERG: It is a bar of some sort.

BY MR. WEINBERG:

Q Correct?

A We were at a train station in Leipzig, and there was a bar called the DB Bar, which we thought was amusing because DB means something very specific in Scientology, it means degraded being.

Q And you were there with Ms. Caberta, we heard about, the German government official that works against Scientology, right?

A Correct.

MR. WEINBERG: I’ll play this clip here. This is something turned over to us by the Lisa McPherson Trust.
______________________________________

(WHEREUPON, the video was played.)

“Okay, so — so, Stacy, you start. DM, this drink’s for you.

“DM, this is a special toast to you coming

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straight from the DB Lounge in Leipzig, Germany.

“I’m not going to call this guy DM anymore. Remember what my new name for David Miscavige is, the former ecclesiastical leader of the Church of Scientology.

“I know this is going on camera.

“I know, but what did I say — (inaudible).

“Yes — yes, this is — this is a toast to David Miscavige, also known as Pope David I, from the DB lounge in Leipzig, Germany. Up, up, up and away.

“Now, Ursula.

“Hi, Mr. Miscavige. We did a great work here in Germany. And we will finish Scientology soon.

“This is to you, Miscavige. We are so thankful that you give us reason to live. Salute.

“Pope David I. Cheers.

“Cheers.

“Just some DBs hanging out here.

“David I.

(Inaudible.)

“This is to David Miscavige in the DB Lounge in Leipzig, Germany at the train station.

“Pope David I.

“Cheers, Miscavige.

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“Rear Admiral.

(Inaudible.)

“Listen, listen, just —

“No, just stop here now. Now listen.

“We all know in Grady’s deposition, when Grady was deposing David Miscavige, that he went ballistic over the thought of Graham —

“Now —

“– of Graham Berry spending time –”

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q Does that bring back memories, Mr. Prince?

A Yes.

Q And you think that is funny?

A Well, what I think you have is a home video of our trip in Europe that was never made public — Mmm — to anyone. And we were just having fun. Yes, I do think it was funny. We were just having fun at the train station.

Q Does that man, Mr. Minton, look like the most harassed person on the face of the earth?

A He does, to me.

Q And when Ms. Caberta, the German official who has — who flew over here and who is working against Scientology, when she said, “We’re going to finish

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Scientology,” she was talking about getting rid of it, wasn’t she?

A No. I think she was specifically talking about Scientology isn’t viewed as a religion in Germany.

Scientology is viewed as a political group. The reason Scientology is viewed as a political group —

THE COURT: I don’t need to know that.

THE WITNESS: Okay.

THE COURT: I don’t need to know, care, what is going on in Germany.

THE WITNESS: Okay.

BY MR. WEINBERG:

Q When you talk about the reason for living, when you-all were talking about, you know, David Miscavige gives us a reason to — a reason for living — reason to live for, talking about so that you can malign him, is that what
you-all are talking about?

A No. Not at all.

Q And do you remember — it was cut off at the end.

Do you remember that — that at that point, Mr. — Mr. Minton said something very obscene about Mr. Miscavige?

A I do not remember that. But, again, I’ll state that this was a video that we made on our trip that was a private video, never made public, never put on the Internet, and it is being exploited here today.

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Q Well, it sort of gives you a different impression about what you-all were about, doesn’t it?

A Who is you-all?

Q Excuse me?

A Who are you talking about, you-all? What you-all were about. What are you talking about?

Q You, Ms. Brooks, Mr. Minton?

A The —

Q The A team?

A I didn’t get that impression.

Q Now, who took that video, this home video that ended up in the LMT on this trip that was financed by the LMT?

A I think Mr. Bunker.

Q So he was there, too, obviously? Was anybody else on this trip? You have the A team, you have Mr. Bunker. Is there anybody else on it?

A Not that I specifically recall.

Q And you-all thought the DB was kind of funny because that is a Scientology term?

A Correct.

Q Now, after looking at your obscenities in front of the Ft. Harrison about Mr. Miscavige, watching this toast, you still think that he would be your friend? Wasn’t that your testimony this morning?

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A You know, I’m talking to a camera there. The answer to your question is yes, I think that if he and I sat down and actually had a discussion, we would certainly find friendship, would be able to communicate.

I mean, isn’t Scientology all about helping people learn —

THE COURT: That didn’t really answer the question. You have that opinion and that is fine. Then that is the answer to the question.

BY MR. WEINBERG:

Q You talk about counseling. The principal purpose of the LMT, when it moved into Clearwater, was for the A team and the people that were working for the A team to picket and harass Scientology, wasn’t it?

A That is incorrect beyond belief.

Q Okay. Now —

A I would like to explain that, if I could. I would like to explain why the LMT came here, since you brought it up, and if you would allow me to just fully answer the question.

Q So you were involved in the —

THE COURT: I’m going to let him answer the question. What was the purpose of the LMT that — what do you believe the purpose of the LMT was?

THE WITNESS: The purpose of the LMT —

THE COURT: Fifty words or less.

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THE WITNESS: Okay, fifty words or less, and I won’t talk too fast for the court reporter.

THE COURT: That is 25.

THE WITNESS: When Lisa McPherson left that hotel, she had no place to go. She had a minor accident, stripped off her clothes, told people that she needed help. She ended up back in the Ft. Harrison. Seventeen days later, she was dead.

The reason that Lisa McPherson came to Clearwater and the reason it was there, in case there was another instance where someone needed a safe place to go where they could come and get help.

That is why we were there. And that is the only reason we were there.

And those were the dying wishes of Fannie McPherson, Lisa McPherson’s mother, when she was on her deathbed.

BY MR. WEINBERG:

Q So all of this picketing which happened on a regular basis, correct —

A Incorrect.

Q Well, can you, like, give us an estimate of the number of times you participated in a picket against the Church of Scientology?

A Yes, I can. Let me think. Because I certainly

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remember the first one well enough. I think I have probably been involved in maybe six or seven pickets.

Q So in the —

THE COURT: Over what periods of time, Mr. Prince?

THE WITNESS: From 1998 to the present.

THE COURT: All right.

BY MR. WEINBERG:

Q So in a four-year picket —

THE COURT: Four-year period. Not picket.

BY MR. WEINBERG:

Q Right, I have picket on the brain. In the four-year period, you say you only picketed six times?

A I roughly estimated six or seven times that I picketed, yes.

Q And do you have a sense of how many times Ms. Brooks and Mr. Minton picketed in that four-year period?

A I do not.

Q A lot more than six?

A I believe so.

THE COURT: He said he didn’t know.

MR. WEINBERG: I believe he just said “I believe so.”

BY MR. WEINBERG:

Q Now, in Clearwater there were other people in the

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LMT that participated in pickets, including Peter Alexander, correct?

A Yes.

Q Patricia Greenway?

A Yes.

Q Frank Oliver?

A I — I can’t say that I have ever seen Frank Oliver carrying a sign, picketing.

Q So you are not aware he picketed?

A Correct.

Q Of course Minton — of course, the A team, right?

A You know, I think Stacy herself maybe picketed maybe five or six times, as well. But then she didn’t do it anymore because it was not anything she agreed with, nor did she feel it was effective in handling the problem that we
were dealing with.

Q Well, let me ask you this. Do you remember that on September 2, 1998 you and Mr. Minton participated in a picket in Boston at the Boston Airport?

A At the Boston Airport? We — I think you have that in complete reverse. Scientologists picketed us at the airport.

Q Do you have signs, “Scientology, The Third Reich”?

A Do I have signs?

Q Did you-all, you and/or Mr. Minton?

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A Mmm, it’s a possibility. I don’t know.

Q In September of ’98 did you and Mr. Minton picket in front of the Church of Scientology in Boston?

A That is possible.

Q Well, that is when he was actually arrested for assault and battery. Right?

A Correct.

Q In October of 1998 did you picket with Mr. Minton in front of the Church of Scientology in Boston?

A It’s possible.

Q You remember several pickets in Boston in October of ’98 with one of Mr. — one with Mr. Minton and one with Ms. Brooks?

A I don’t remember that specifically, no.

THE COURT: Tell me why we have to spend so much times on these pickets.

MR. WEINBERG: Because, your Honor, it — it — it demonstrates — first of all, it puts the lie to what we’ve heard all of the way through —

THE COURT: But I know that this man has been involved in pickets.

MR. WEINBERG: It is way beyond that, your Honor. I mean, really —

THE COURT: Pardon?

MR. WEINBERG: It is way beyond that. You have

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before you a harassment time line. And Mr. Dandar has spent literally 28 days suggesting that somehow Mr. Minton was harassed to the point where — where, for reasons that don’t make any sense to me, for that purpose he would come in and incriminate himself.

And the fact is — we’re not playing all of the pickets. But when you see these clips, most of which we got from the Lisa McPherson Trust in these videos that were just turned over, you will see what was really — what was happening here in Clearwater.

THE COURT: I have no doubt that at the LMT Trust they had very little use, if any, for the Church of Scientology. And they picketed them fairly regularly. Quite frankly, if they had fallen on their face, they wouldn’t have cared; that they were out, in essence, to undo what they perceived to be the bad things that they perceived the Church of Scientology did. I don’t have any doubt about that.

I think the record is clear. So I don’t know why we keep going over those things.

There are things that are really critical to this hearing. And I don’t think those are it.

MR. WEINBERG: Well, I mean —

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THE COURT: It might be important to the counterclaim, but not to this hearing.

MR. WEINBERG: Well, I mean, if you rely on, for example, what Peter Alexander said, he said he didn’t have anything — or essentially nothing to do with it. You’ll see essentially the opposite.

You have heard that somehow Mr. Minton was harassed. And you’re going to see what was really going on, that the Church was harassed beyond comprehension.

THE COURT: I have no doubt Mr. Minton harassed the Church, as well as the Church harassed Mr. Minton. It is just that simple.

MR. WEINBERG: But nothing is more — well, can I proceed with my cross-examination?

THE COURT: Yes. You may.

MR. WEINBERG: Thank you.

BY MR. WEINBERG:

Q You went on the Internet, as well, didn’t you?

A I have been on the Internet. Yes, I have.

Q You made postings on the Internet?

A Yes, I have.

Q In that Leipzig toast you — instead of using the name “David Miscavige,” you actually said “Miss Cabbage,” didn’t you? That was a little joke, wasn’t it?

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A Did I say that?

Q I’m asking you.

A I thought I said “Miscavige.”

MR. DANDAR: I think we need to hear the video, rather than someone’s transcript.

MR. WEINBERG: I’m going to show you a posting.

THE COURT: In a posting we have heard him called Rear Admiral. We know what that means. And we know they called him Miss Cabbage. And they don’t speak kindly of David Miscavige.

MR. WEINBERG: I understand that. And I’m going to show him, have him identify, his Internet postings.

A I will admit — I have said that before, Miss Cabbage. I just don’t know that — if that is what you are seeing there.

MR. WEINBERG: Could I stand up here with Mr. Prince?

THE COURT: You may.

MR. WEINBERG: I have no other copies.

THE WITNESS: I have no idea what this is.

BY MR. WEINBERG:

Q This is your postings, isn’t it?

A Excuse me?

Q This is your postings?

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A I don’t think so. I think it is a fictitious document created —

Q So you didn’t send a posting that said:

“Too bad, Little Miss Cabbage has a corncob up your ass, 724365. I know the feeling. That is why I have him reeling, spending money like a bitch kicked from a pimp. Roll on, ho, big daddy can see you. Jesse.”

A Yes, correct. But that is a fictitious document that was created for the purpose of — to malign me.

Q To malign you?

A Yes.

Q But you have used Miss Cabbage?

A Yes, I’ll admit it. Freely admit it.

MR. DANDAR: Objection. This does not have the normal E-Mail headers on it that you would find if it was an original document, instead of something that someone altered.

A I don’t even know who Robert is.

THE COURT: I don’t know. If he can’t authenticate that, I don’t know whether — I don’t know whether it is in or not. At the top it says

“Spread the word, bitch.”

Then it goes on to some other comments. And that is not the way an E-Mail normally —

MR. WEINBERG: It is not an E-Mail. It’s a

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posting.

THE COURT: Well, the same thing. I don’t know. It would seem like this Jesse Prince, Jesse77@GTE.net would be Mr. Prince’s — that would be — is that what you go by?

THE WITNESS: I had that in 1998, I think, when I had a particular type of computer, I used to have that address. But as I sit here today, I don’t know what name — the name Robert.

BY MR. WEINBERG:

Q Well, when you use the word “Miss Cabbage,” what do you mean?

MR. DANDAR: Objection. That is not his E-Mail.

THE COURT: No, he admitted that he has called David Miscavige Miss Cabbage.

A It’s an obvious derogatory use of Miscavige.

BY MR. WEINBERG:

Q And derogatory in — I mean, in what context did you use it when you used it?

A I don’t remember. I just know that — you know —

I have said that before. I admit to it.

Q Now, let me show you — see if you recognize this posting. Or is this another fictitious one?

MR. WEINBERG: What will this be?

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THE CLERK: 219.

MR. DANDAR: What exhibit number is that?

MR. WEINBERG: 219.

THE COURT: The one before that was 2-what?

MR. WEINBERG: 218.

THE COURT: That did not come in because —

MR. WEINBERG: He said he couldn’t authenticate it.

THE COURT: So that is not in evidence. That is Number 218. This one you just gave us is 219?

MR. WEINBERG: Yes, your Honor.

THE COURT: Okay.

THE WITNESS: Okay.

BY MR. WEINBERG:

Q Did you make that posting?

A Yes, I did.

Q And do you consider that to be a — a posting that would indicate a derogatory view toward Mr. Miscavige and the religion of Scientology?

A Mmm, I think that this posting is a result of the Scientology operations being run on me.

While I’m trying to testify in a court in front of a judge in Denver, Scientology hired a prostitute, had a deep undercover agent, Laura Terepin, working on me, helping me with the deposition, saying there are people other than

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who they are. You know, this is an annoyance response to what had been happening to me. You see I clearly speak about private investigators following me.

In Denver, very strange things happened.

Q What do you mean, they hired a prostitute?

A A prostitute.

You know, this guy from Denver — there was a private investigative agency in Denver that was watching me. He brought a woman who said it was his sister, who was a whore. She got a room directly across the street from my — not across the street, across the hall from my room in the hotel that I was staying in.

And when I came out — and she was a beautiful woman, you know. “Oh, can you help me get my key,” on and on and start this conversation.

This guy says, “This is my sister. We’re just in town.”

Suitable guise. Mr. Sharp will explain it to you. And they started this whole routine of, “Come on. Party with us tonight. We’ve got drugs, we have this. We’ve got whatever.”

I’m supposed to testify. I literally had to get rid of them.

The other person, Laura Terepin was — her real name wasn’t Laura Terepin.

Jolie Steckart, specifically paid by Scientology

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to infiltrate Mr. Dan Leipold’s office as I sat there writing my declaration for his case.

It was these kind of things that annoyed me, and I would write these things.

Q So when this hooker came to your room, you told her to leave?

A Yes.

Q Or did you —

A We were at the bar. And then she wanted to come to the room. I’m like, “No, I have to testify.”

Q But I think you testified previously that she actually — you let her come to your room and you did something with her. Right?

A No. I don’t think so. I don’t think so. I — I think that you are fabricating that.

Q Now, when you say in the first sentence: “It seems some people (Miscavige) just don’t have the guts to quit when it’s over,” what did you mean by that?

A What I meant specifically by that is that I came into the case — the FACTNet case — Scientology had brought an action against FACTNet for copyright — certain copyright violations.

And — Mmm — I — I remember vividly the whole issue of copyrights in Scientology. I have given a — a detailed affidavit about it.

But the fact of the matter is the copyrights — or

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at least some of them — were completely bogus. And the filings of the copyrights were filed under false premises.

I did an affidavit against that concerning that — concerning that naming specifically the people that were involved. Another officer, staff member, Pat Brice, was involved, because after Mr. Miscavige dismantled the Guardian’s Office, there was always a section in Scientology, according to its own policy, to register trademarks and copyrights all of the time.

Q That is what you meant —

A Excuse me I’m still talking. And they let that lapse a period of time. So you had a large section of materials that they claim copyright protection for which, in fact, they did not have. And I was able to identify what that was.

Q So that is what you meant when you said, “When it’s over, they just don’t have the guts to know when it’s over”?

A Correct. They submit false documents to the Court. I point out to the Court that the documents are false and show them how, is specifically what I mean there.

Q The third paragraph, the last sentence, where you say: “Can’t you just –” talking about Miscavige now, “Can’t you just take it like a man? Soon you’ll be in a place where you’ll be taking it like a man regularly,” that

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is sort of like the Miss Cabbage thing, you’re talking about him being in jail and sexually assaulted?

A I’m talking about him being incarcerated for being involved in criminal activity.

THE COURT: Was this a posting to David Miscavige, or somebody else?

THE WITNESS: No. It was that newsgroup, alt.religion.scientology.

BY MR. WEINBERG:

Q Let me show you another one. You did hundreds of these things?

A I don’t think so.

Q You just felt compelled, as an expert, to go on this alt.religion.scientology and say obscene things about David Miscavige?

A At the time of these writings, I was not operating — I don’t think I was — I don’t know. I don’t remember. I don’t think I was an expert in this — I think I came in here in December of ’99 when —

THE COURT: I mean, there are people that learn things from this case. Mr. Prince, if you are going to ever testify in another case, you ought to learn not to post things on an Internet, especially not to be involved in vulgar demonstrations. They’ll always come back to haunt you in a court proceeding.

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Just like I hope Mr. Dandar learned, whether you call it picket or vigil, if you are a lawyer, you ought not to be there.

There are certain things you need to have learned. I hope you learned that.

THE WITNESS: Your Honor, that is a true statement. I have learned that from Judge Moody. He taught me quite a bit about how I needed to act in relationship to this.

And you are right, I have had some indiscretions. All right, if we need to talk about that, we will.

BY MR. WEINBERG:

Q I showed you what I marked as Defendant’s Exhibit 220. Do you see that, Mr. Prince?

A Yes, I do.

Q Do you remember writing that open letter to David Miscavige?

A Uh-huh.

THE COURT: That is a yes?

THE WITNESS: Yes. I’m sorry. Yes.

BY MR. WEINBERG:

Q And — and this is when you are definitely involved as an expert, you already worked on Wollersheim, you already reviewed the PC folders for Mr. Dandar.

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Correct?

A Quite possibly I’ll agree with you there.

Q And so you say in the first paragraph: “How desperate you must feel. If you sit quietly and listen carefully, you will hear it.”

MR. DANDAR: Objection. I need to have the question asked of the witness to identify this document and make sure it is his.

MR. WEINBERG: He just did.

A This is my document. Yes.

MR. DANDAR: It doesn’t have headers on it. That is all.

THE COURT: Well, he has identified it, so —

MR. DANDAR: All right.

A Yes.

THE COURT: You are introducing this?

MR. WEINBERG: Yes, I am.

THE COURT: It will be received.

MR. WEINBERG: And I —

THE COURT: Honestly, I’ll tell you the same thing, I don’t need you to read it to me. If there is some part you want to point to —

MR. WEINBERG: Really, the first paragraph and last paragraph.

THE COURT: Okay.

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A Yes, I wrote — I wrote the first paragraph, all of the paragraphs in the middle, all of the way to the end.

And I think if you read this whole thing, you’ll see that I’m upset, I’m very peeved over the fact on Page 2, second paragraph, that —

BY MR. WEINBERG:

Q I didn’t ask about Page 2. I asked about the first paragraph. That is all I asked you.

A Oh, okay.

Q And the last paragraph. You wrote that, where you quote the Bible?

A Correct.

Q And the reason for quoting this passage from Revelations about “Avenge our blood on those who dwell upon the earth” was what?

A Well, you know, if you know this passage, these are the saints that died for righteousness but evil and corruption carries on. And when the fifth seal is opened, biblically speaking, the saints’ blood will be avenged.

This is specifically what I’m talking about. And how this relates to Miscavige and Scientology is the corruption — the agonizing activity that I had to go through to deal with my children, my father, old girlfriends, Scientology did their noisy investigation on me.

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I wish I would have had this document when Mr. Dandar was asking me do you remember noisy investigations. They ran around to my entire family. I had to go to Chicago, I had to go to Minneapolis, to Memphis, Tennessee, to deal with friends and associates and family as a result of Scientology doing their, quote/unquote, noisy investigation, spreading lies and false information about me.

THE COURT: Are you done with Number 220? We need to take our break.

MR. WEINBERG: We offer 220. And I do also offer 219, the one before that.

THE COURT: That will be received, too. And we’ll go ahead and take our afternoon break. It is 25 after. A 20-minute break.

MR. WEINBERG: Thank you.

(WHEREUPON, a recess was taken from 3:25 to 3:50.)
______________________________________

THE COURT: You may continue.

MR. WEINBERG: Thank you. At the break I had one more of these things I was going to mark. I’ll go on. That is 221.

BY MR. WEINBERG:

Q Now, Mr. Prince, do you recognize Defense Exhibit 221 as a posting which you made on or about August 6 of

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1998?

A If you’ll give me just one minute —

Q Sure.
A — to review this document, please, I’ll indicate it for you.

Okay, yes. I do remember this document.

MR. WEINBERG: All right. I’ll offer this, your Honor. I have a couple questions to ask on it.

THE COURT: All right. It will be received.

BY MR. WEINBERG:

Q Now, this is one of the first postings you made after you had joined the ranks of working against Scientology, correct?

A I would hardly characterize it as that. But this is one of the first postings that I made on the Internet concerning Scientology. Yes.

Q All right. Now, in that first paragraph you say, second sentence: “You know, I just can’t refer to Scientology as a church in any way. It would be an insult to all religions.” Do you see that?

A Yes.

Q And that is how you feel today, isn’t it?

A You know, it is not. And I can explain to you why.

Q You don’t need to.

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A Okay. Then I have answered the question.

Q So you think it’s a church?

A Correct.

Q So you just sent this out of some hatred?

MR. DANDAR: Objection. He didn’t want him to explain it. Now he’s asking him. So let the man explain his answer.

THE COURT: Well, I think that was a different question. And I think that Mr. Prince is capable of answering that question, then I think he can explain it.

BY MR. WEINBERG:

Q You sent this out of some hatred for Scientology?

A Mmm, no, sir.

Q Now, if you go to the fourth paragraph where it says, I quote:

“The bottom line is that the hierarchy of Scientology is composed of people who are very, very, very mentally ill, sick people of the worst sort. Why? Because they are sick and don’t know it. In all honesty, I hope to reach them so they can wake up and start getting well like I have and others have.”

You wrote that, right?

A Correct.

Q Wasn’t that what you have, in essence, been doing for the last four years, trying to get rid of the hierarchy

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of Scientology, including David Miscavige?

A You know, that is not exactly what I say here, to get rid of those people. I said I hope that I could reach them so that they can wake up and start getting well themselves.

Q Now, you — the truth is, isn’t it, Mr. Prince, that you and Mr. Minton and Ms. Brooks, the A team, had a ball with regard to all this picketing you-all participate in over the last four years?

A I’m sorry, I hardly can agree to that, Mr. Weinberg. I wouldn’t call it a ball.

Q You had a lot of fun doing it, wouldn’t you say?

A I wouldn’t say that either, Mr. Weinberg.

Q You remember the first time that you went to New Hampshire and — and — and encountered picketing in New Hampshire?

A Yes, when Scientologists came in and picketed Mr. Minton’s home.

Q Right. And that was on Mr. Minton’s — that was on Ms. Brooks’ harassment time line. Right?

A It very well could have been. Sure.

Q And do you remember that you were there with Mr. Minton and that you-all were laughing and giggling and making fun of the Scientologists, the few that came by in the cars? You called it a drive-by —

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A The picketers, yes, it was amusing because the Scientologists came by and stood in the road with their signs, and it is quite a narrow road up in New Hampshire, there aren’t sidewalks where Mr. Minton lives. So a state trooper came and asked them not to stand in the road because it was dangerous. It was actually kind of a blind curve by Mr. Minton’s house that makes it dangerous, being there are no sidewalks.

And what was particularly amusing about what the Scientologists resorted to at that point is that they — Mmm — went around and pulled their cars way back, then took their picket signs out the window, because they were too big to stick through the window, and they held them outside of the car and drove back and forth. I thought that was pretty pathetic.

Q And you and Mr. Minton had anti-Scientology signs, correct?

A Mr. Minton had signs.

Q You did, too?

A No. I never owned a picket sign myself.

Q You never held a picket sign?

A I never owned —

Q I didn’t ask you whether you owned it.

A I’m sorry.

Q You had a sign. There were signs there that you

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and Mr. Minton had, correct? Anti-Scientology signs?

A That may or may not be correct. I don’t specifically recall.

Q All right. Do you remember doing a posting with regard to that incident that appears on the harassment time line?

A I do. But — but, Mr. Weinberg, I have to say this because, you know, you selectively are taking paragraphs out of these things and you are painting a picture here.

But really what this is about is — this last thing you handed me is about trying to help these people. I’m telling the story about something that happened to Marty Rathbun, something that might have had a psychological
impact on him that he would need help resolving.

Q But that wasn’t my question. All my question was, you did another posting about this incident which appears on Mr. Minton’s harassment time line in front of his house in 1998. Correct?

A You know, I need that time line right here. I mean, I’m saying it’s possible. But if you want to pull it out, you want to show me what you’re talking about, I think I can answer the question better.

Thank you.

MR. WEINBERG: Marked as 222.

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BY MR. WEINBERG:

Q You can identify this as your posting, can you not, Mr. Prince?

A Yes.

Q And in the second paragraph you say, “Bob and Jesse quickly helped with the pilot and started bullbaiting the protesters.”

When you say bullbaiting, that would suggest that you were, what, holding signs or doing something back?

A No. Bullbaiting is a term that is used in Scientology specifically to designate some of their training routines. The training routines are called TRs; TRs for short.

Part of the training routine is to be able to sit across from a person without flinching and without moving when the person makes gestures or tries to do something shocking; in other words, this is a routine to train you to keep your countenance during an adverse commission, I guess.

Q In here you said, “We had great fun”?

A Correct.

Q Now, do you know why this appeared on the harassment time line if it was so much fun?

A Well, you haven’t shown me that — and I have asked you, too, to show me on the time line. So I can’t answer these questions — you know, you are referring to

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something that I don’t have in front of me. I can’t see it.

Q I thought from the testimony yesterday that you had reviewed the time line pretty closely?

THE COURT: Well, believe me, he has. It’s a very long thing. I think it’s a fair request. If you want him to specifically note whether it is on the time line or not, show him the time line.

MR. WEINBERG: I will.

THE COURT: My recollection is that document was extremely long.

MR. DANDAR: It is. And, Judge, I object to 222 because there has definitely been editing done. Right after “barbecue” and before the word “soup,” something is taken out.

MR. WEINBERG: No, it is not. You knew exactly what it is.

THE WITNESS: Where is that at?

MR. DANDAR: Where it said, “You invited Minton for barbecue,” after “barbecue” there is a blank, then there is “soup.”

THE COURT: 222, you are talking about?

MR. DANDAR: Yes. Right here.

THE WITNESS: Second paragraph? Oh, yes, you are right. You are right. It has been edited.

Something has been deleted from there.

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BY MR. WEINBERG:

Q What was there? Because we didn’t edit anything.

A Yes, maybe you didn’t, but your client did. And I know specifically why.

What it said, “We were having BT and cluster soup.” BT is part of the secret cosmology of the upper levels of Scientology. So this has been, in fact, edited.

MR. DANDAR: I object to it. It is an altered document.

MR. WEINBERG: Are you testifying, first of all?

MR. DANDAR: I’m objecting to it based on Mr. Prince’s testimony. It’s an altered document by the defendant.

MR. WEINBERG: He identified it before, your Honor.

THE COURT: Well, Mr. Dandar just indicated that it had been altered. And so if it now — I’ll ask you, Mr. Prince, is that the original document, or has it been altered?

THE WITNESS: Yes, your Honor, this has been altered. This is not the original.

THE COURT: If you have one that has not been altered, then it will be admissible.

MR. WEINBERG: First of all, we didn’t alter

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anything.

THE COURT: I didn’t say you did. But if — I mean, I’m happy to write in the original what was there if Mr. Prince remembers it and everybody agrees.

BY MR. WEINBERG:

Q Do you remember what was there?

A I remember exactly what was there. It says we were having barbecue BTs and cluster soup. “BTs” and “clusters” are words Scientologists aren’t allowed to use outside of Scientology.

Q So it’s a derogatory thing?

A No, there is nothing derogatory about BTs and clusters. This is a reality – something they believe in.

Q Well, I —

A But they are sensitive to it, so they altered the document.

MR. DANDAR: And I would object. If there is any more altered documents, that they not attempt to use them, or tell you in advance.

THE COURT: You just heard counsel say he did not know or believe it had been altered. So be careful, though, when you look at your documents.

That does look like something is missing from there. But I do know on my own E-Mails sometimes they

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all get askew and don’t seem to line up right. I was on the Florida Supreme Court website looking up stuff on the death penalty cases. And all of a sudden they go and they just stop. So you can’t tell by looking.

MR. DANDAR: But this one —

THE COURT: That one does appear to be where there is something clearly missing. So —

MR. WEINBERG: It obviously was not what I was focusing on, BT and cluster soup. But with the record indicating what Mr. Prince was saying was there, I offer the exhibit.

THE COURT: Take the original back and write it in.

MR. WEINBERG: Sure.

THE COURT: And ask Mr. Prince if that is what he recalls it said and, if so, then we can admit it with that —

MR. WEINBERG: I’ll let him write it because I don’t know — I assume how to spell it but I’m not sure how to spell it.

THE COURT: BT , is that like two initials.

THE WITNESS: Yes.

BY MR. WEINBERG:

Q Here. Do it like this.

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THE COURT: Everybody make notations on your copies. Cluster is C-L-U-S-T-E-R.

THE WITNESS: Yes, your Honor.

MR. WEINBERG: Okay. And the original has “BT” and that he wrote in.

THE COURT: Okay. That will be admitted.

BY MR. WEINBERG:

Q Now, you remember that at this —

A Excuse me.

Q I wanted to show you the harassment time line. Let me show you what has been previously marked as the harassment time line, the “Time Line of Scientology Harassment of Robert Minton and Colleagues.”

I show you the entry for September 7, 1998. It says: “Scientologists picketed Mr. Minton’s home in New Hampshire again but it was done in a car with picket signs held out of the car window.”

A Correct.

Q So that was the incident, right?

A Yes.

Q Now, I want to play this. This is that — you remember you-all videoed this?

A I don’t remember videoing the incident, but let’s see what you have got.

Here is your pen, by the way —

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______________________________________

(WHEREUPON, the video was played.)

“Don’t block her sign now, Jesse. I’ve gotta get a picture of that good sign.

“Okay. Let me put mine up.

“Okay, yeah.

“Hey, Maureen, just out here having a little chat.

So did you see that last — “(Inaudible.) I don’t know. All I can say is when I was in your position, there was a lot of —

“That you’re a staunch Scientologist. And it’s dangerous for you to believe otherwise because you’d be wrong.”

MR. DANDAR: Could we clarify the people in the car are Scientologists?

BY MR. WEINBERG:

Q They are, aren’t they, Mr. Prince?

A They are. OSA personnel.

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______________________________________

“Damn dumb asses. I got ’em. See, what they need, what they need is like a — what they need — what they need is a chain — I mean a long line of cars.

“They just don’t seem to be able to get more than two —

“Yeah.

“– for these little New Hampshire things.

“Hey, it’s an hour from Boston, man.

“Ain’t it pathetic. One person holding one sign out the window. And then when they go by this way, the driver can’t do it so the fucking sign’s over there. Oh, my God. How pathetic.

“They must think this is having some kind of terrible psychological impact.

“Yes, it’s just entertaining as all hell.

“Here they come.

“Okay.

(Inaudible.)

“Hey, you fucking idiot.

“They don’t have enough nerve to try to run over me.

“Me, either. I stood there, too. I just stood in the middle of the road and got ’em driving up.

“Look at this. This is a good one.

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“Here they come again. That’s when they were coming earlier. That’s all I got of them so far, but the two of them are good.

“Yeah.”

(End of playing of the video tape.)
______________________________________

MR. WEINBERG: That is it?

BY MR. WEINBERG:

Q So you were having fun, you and Mr. Minton, in this thing on the harassment time line?

A Mmm, you know, Mr. Weinberg, I think even I said on that tape it was just an annoyance that they do it; though it was pathetic and though it was funny, it’s annoying. Now, you made a huge point about how harassed Scientology feels about being picketed. But when these people come by and picket, we’re supposed to be having fun. You can’t have it both ways.

Q Well, what do you call what they were doing, by the way? Do you call that harassment? Or do you call that the First Amendment?

A They were exercising their First Amendment rights.

But what happened that was harassing is that Bob and I didn’t have a clue they were even out there until they parked their cars, ran up to the door, knocked on the door

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screaming, “Minton, Minton, Minton,” then ran back to their cars. This is the only way they let us know they were there.

We are upstairs fooling around on the computers. These guys are banging on the doors. We wonder, what the heck. We run down. And we got the drive-by pickets going on.

Q They didn’t shout obscenities?

A Absolutely. “Where is your whore, Minton?” This kind of thing. Absolutely.

Q You didn’t hear that on the tape, though, did you?

A Well, of course not. Because what I’m speaking about is when they knocked on the door, and we were way in the back of the house. They wanted to make themselves known. Now, what they’re doing, going up and down there,
okay.

Q Now, after this, after September of 1998, was this your first encounter with picketing, having signs and stuff like that?

A It could have been.

Q Now, after this, for the next — for the next four years, or almost four years, Mr. Minton and you and Ms. Brooks and other people affiliated with the Lisa McPherson Trust did all kinds of pickets in front of Scientology buildings, shouting obscenities, making threats,

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interfering with — with Scientologists going into their buildings and the like, didn’t you?

A That is categorically false.

MR. WEINBERG: Could you play the first tape, please. This is May 27 — this is again — this is the Lisa McPherson Trust.

______________________________________

(WHEREUPON, the video was played.)

“Stick this in the right place. Scientology is a scam. A white meter. Fucking criminal. David Miscavige is a white Jew. He will be a convicted criminal.”

(End of playing of the video tape.)

BY MR. WEINBERG:

Q Now, do you consider that harassment of the Church of Scientology? That was out in front of the church in Boston, wasn’t it?

A Yes. Was I there?

Q I’m asking you, do you consider that harassment?

MR. DANDAR: Objection. He’s not there. He should not be asked to comment about —

THE COURT: I think he can comment on that.

Overruled.

A You know, what I see there, that little snippet that you showed me, I would say yes, that is a bit annoying

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and harassing.

But I also suspect, because when Bob Minton would go out and picket, he would just be quiet, he wouldn’t say a word, he would just walk up and down the street.

But then the OSA people would come out, Maureen Garde, the person I was walking with in the previous video, they would come out and start talking to Mr. Minton about things from his therapy sessions.

This is where the therapy information started, in picketing the Boston org. And they would kind of whip him into a frenzy. And the whole idea was to bait Mr. Minton to make him look like an ass.

Well, you know, I agree everyone ended up looking like an ass on some of those things, but, you know, let’s put this in perspective, because these little snips aren’t going to work. These people were specifically targeting Mr. Minton to do psychological terrorism on him.

BY MR. WEINBERG:

Q Now, is it a bit annoying that Mr. Minton said that L. Ron Hubbard and David Miscavige were wife beaters?

That is a bit annoying?

A And I’m sure he’s annoyed because Mrs. Maureen Garde started speaking to things about — from his confidential counseling sessions with Scientology.

How Scientology got that information, God only knows, because no one will ever speak on it, will they? But that is what was

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happening there.

Q And Mr. Minton, according to your testimony, was quiet on his pickets?

A He would just be as quiet as hell. Then if he got antagonized, he would start in. And I think that was known.

And, you know, you talk about me hating Scientologists. When you saw me in that first —

THE COURT: We’re well past the answer to that question.

THE WITNESS: Okay.

MR. WEINBERG: Play the next one, please.
______________________________________

(WHEREUPON, the video was played.)

“Reform Scientology now. Don’t let David Miscavige destroy Scientology. L. Ron Hubbard would not approve of what David Miscavige has done.

“It’s safe to look. It’s safe to talk. Don’t let David Miscavige destroy the Church of Scientology. Make it something you can be proud of. Dump David Miscavige. Dump David Miscavige. It’s safe to talk. It’s safe to look. Don’t let David Miscavige destroy Scientology. L. Ron Hubbard would never approve of what Miscavige is doing. (Inaudible.)

“Reform Scientology now.

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“Don’t let the introspection rundown kill you. You don’t have to die in introspection rundown. You don’t have to let Miscavige scare you to death.

“Don’t be afraid.

“Don’t let Miscavige scare you out.

“It’s okay to confront the fact that Miscavige cannot handle some pressure.”

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q You recognize that as people including Mr. Minton from the Lisa McPherson Trust, right where the Scientologists in Clearwater go to eat, right? That is where that was, wasn’t it?

A Yes, it was.

Q And that sure sounded like a direct attack on David Miscavige, didn’t it?

A Mmm, it sounded like there was definitely some problems with Miscavige being voiced there.

Q You saw Miss Greenway there, didn’t you?

A Yes.

Q You saw David Cecere from the Lisa McPherson Trust?

A Yes. I didn’t see me, though.

Q You were the vice-president of PR at the Lisa

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McPherson Trust, weren’t you?

A That is such a fabrication, it is laughable. I have never been — had anything to do with public relations, period. Can’t you tell?

Q So what was your position at the Lisa McPherson Trust?

A I was there specifically to help people who had been in — somehow had some gripe with Scientology that they wanted to make right.

And again I’ll say it. The work that we were doing at the Lisa McPherson Trust helped Scientology because you had a lot of garbage in the street, people that were hurt, people giving you a bad name.

When we finished with those people, they signed releases saying they wouldn’t speak disparagingly about you again, they got their money and they went on their way. Okay, that part needs to be told.

Q My only question was what was your title or position in the Lisa McPherson Trust?

A Vice-president.

Q Vice-president of what?

A The Lisa McPherson Trust.

Q And what was your responsibility there?

A I’ll say it again.

THE COURT: He just already said that.

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MR. WEINBERG: That is just what he said?

THE COURT: Yes.

BY MR. WEINBERG:

Q Now, were you referred to as the big boss at the Lisa McPherson Trust?

A No.

MR. WEINBERG: Play the next one, please.

_____________________________________

(WHEREUPON, the video was played.)

“Make Scientology something to be proud of. Reform it now before David Miscavige ruins it. Find the new leaders within your organization whom you can be proud of.

“Stacy, why don’t you try to round some of them up?

“The Lisa McPherson Trust was established at 33 North Ft. Harrison Avenue in order to let the world know about the abusive practices which David Miscavige has caused Scientology to live by.

“The Lisa McPherson Trust will always be here to remind you that you have a responsibility to be good human beings. David Miscavige is ruining your organization.

“Telecommunications is one of the powerful things you have learned in Scientology. Use it.

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Try to use it to make the world a better place and start with dumping David Miscavige.

“If you ever want any help from Scientology, you can run to 33 North Ft. Harrison Avenue to the Lisa McPherson Trust.

“If you remember, Lisa McPherson is the woman who was held by Scientology for 17 days.

“The whole episode in the Church of Scientology’s Ft. Harrison Hotel was totally out-tech. Even the state prosecutor said it was totally out-tech. The whole thing was run by David Miscavige. David Miscavige is responsible for that woman’s death.

“Remember, David Miscavige is the one who performed the out-tech on Lisa McPherson.

“Remember, David Miscavige was responsible for the out-tech, out-tech handling of Lisa McPherson. She died after 17 days in captivity here.

“It was totally out-tech and you know it. You can look and smile.

“David Miscavige pulled the plug on Lisa. He pulled the plug on Hubbard’s tech. It’s time to face reality. Reform Scientology or it will be destroyed by David Miscavige.”

(End of playing of the video tape.)

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______________________________________

BY MR. WEINBERG:

Q Now, what was the reason that the Lisa McPherson Trust documented all these pickets by taking videos like this?

A Mmm, I think the purpose of the Lisa McPherson Trust always having the video when in close proximity to Scientology is the same reason that — for the same reason that happened to Mr. Minton when David Howe (phonetic) and another staff member — I think that was a staff member that attacked him. I personally took him to the hospital. He just raced him, no one is looking, boom.

So it became routine to take a video camera, in case something did happen that was truly criminal, that it could be documented. That was the purpose.

Q But it was for evidentiary purposes?

A Correct.

Q It wasn’t for posterity?

A Correct.

Q I mean, wasn’t this what the Lisa McPherson Trust was about — let me finish my question — to try to get rid of David Miscavige and to terrorize, using your word now, the Church of Scientology?

A I — I think Mr. Minton was very clear on what the Lisa McPherson Trust was for. And I’m glad you showed that

693

video, because he made it clear he wasn’t out to destroy Scientology, make Scientology go away, as you have, you know, suggested earlier. He wanted it to reform. He wanted the criminal activities to stop.

Why does he pick David Miscavige? I think we need to talk about it. Because you know why? He’s the man that has the private investigators do what they do. He’s the one that — that instigates these vicious attacks against individuals who have any disparaging thing to say about Scientology.

Why does Mr. Minton mention him? Because he knows he’s the person that can change it. Just like that letter that was turned into evidence concerning Bernie McCabe.

He’s the person that can do it. If anyone can do it, Mr. Miscavige can do it.

Q You suggested, stated, in your affidavit, that a decision was made, an intentional premeditated decision, to let her die?

A Correct.

Q This is the same man that you shouted obscenities about, it’s the same man we are watching videos of Mr. Minton and others stand up, asking to be deposed or thrown out of position, right?

A It’s the same man I audited. It’s the same man I have been friends with many years. It’s the same man I have done training with. It’s the same man I helped myself establish and build Scientology for many years. So add that into the equation, too.

Q You think he would call you his friend?

A I think if David and I sat down and talked, he would —

THE COURT: I have heard this question and I have heard this answer at least twice.

MR. WEINBERG: Thank you.

BY MR. WEINBERG:

Q Now, when Mr. Minton said the words “Out-tech” that is something that means something to a Scientologist, correct?

A Correct.

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Q I mean, Mr. Minton, prior to getting involved with you —

THE COURT: Counselor, it is getting pretty bad to me because I understood it.

MR. WEINBERG: But — all right.

BY MR. WEINBERG:

Q A Scientologist, or a judge that sat in a hearing for 28 days.

THE COURT: There you go.

BY MR. WEINBERG:

Q That is not something Mr. Minton or any of us, having not been exposed to Scientology before, would understand, correct?

A Yes.

Q And to be out — out to accuse the ecclesiastical leader of being out-tech is about as — about as serious and severe an accusation as you could possibly make against David Miscavige, isn’t it?

A Mmm, Mr. Weinberg, my answer is if the shoe fits, wear it.

Q Just answer that question.

A I did. If the shoe fits, wear it.

THE COURT: No, he wants to know if that is a serious accusation to make to other Scientologists about their ecclesiastical head. Is that a bad

696

thing to the head of Scientology to be out-tech.

THE WITNESS: Yes, it is.

THE COURT: To another Scientologist, those folks seeing that demonstration, if they believed that, would not think very highly of their leader?

THE WITNESS: Correct.

BY MR. WEINBERG:

Q And would you not — from looking at that video or the other videos that you have seen so far, it doesn’t look like any of the Scientologists are having a lot of fun at your demonstrations, correct?

A You know, you have only shown me specifically Mr. Minton. You haven’t shown me what the Scientologists are doing or not doing, Mr. Weinberg.

Q Well, in that video we just showed, it was —

A It was going back and forth.

THE COURT: You know what, the deal is we are showing this for —

MR. WEINBERG: That is correct.

Could you play the next one, please.
______________________________________

(WHEREUPON, the video was played.)

“Communicate to David Miscavige that he’s fired.

“Remember Lisa McPherson.

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“When you’re eating, remember Lisa at her last meal in December of ’95, held captive by the Church of Scientology leader, David Miscavige.

(Inaudible.)

“What is not safe for you is to stand there and do nothing. Tell David Miscavige he’s wrong. Tell him that L. Ron Hubbard would never approve of what he is doing to destroy your church.

“PK, PK, don’t run away.”

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q Does it look, in that video — I mean, and others that we’ve seen — that Mr. Minton is terrorized, harassed or anything like that?

A Mmm, it looks like Mr. Minton was picketing, to me.

Q Now —
______________________________________

(WHEREUPON, the video was played.)

“Okay, are we going to do the locks?

“But the — are we going to do the alarms or –” (Inaudible.)

(End of playing of the video tape.)
______________________________________

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BY MR. WEINBERG:

Q You were just having a big time, you and Ms. Greenway?

A You know, that is an edited video you have there. It is — there is obvious editing there, so I would be hard-pressed to draw that conclusion.

Q When it started, it started like all of the pickets started inside the offices of the LMT, correct?

A That is a mischaracterization of how pickets started because every picket did not start in the Lisa McPherson Trust. Other people picketed the Ft. Harrison that weren’t associated with the Lisa McPherson Trust or employees of the LMT — Lisa McPherson Trust.

Q That clip from the LMT film library, that one started in the LMT building, didn’t it?

A I don’t know if it started or finished there because you have shown me one tiny segment. So, you know, if I could have some perspective and see the whole thing, I would be able to comment more accurately.

Q Now, the LMT — literally at times these pickets were intended to literally shut down Clearwater around where you-all were picketing, right?

“Last year, we were all over the place in a clump. We shut down here, we shut down here, we shut down there. We had Flag shut down for the whole day, anyway. This year we spread out in strategic spots and shut down the whole city.

“Frank Oliver came and caused the last breach. So far about two hours now they can’t hardly move anybody any way. They can pick up people from Flag but they can’t bring them in because they have to bring them in there, and they can’t do it.”

(End of playing of the video tape.)
_______________________________________
BY MR. WEINBERG:

Q That is somebody from the LMT?

A Absolutely not.

Q Who is that?

A Greg Hagglund. He lives in Canada.

Q And he was down here for the picket in December?

A Looking at that date of that, he was down for the picket and vigil. People come from all over the United States and even Europe for that. They were doing that long before the Lisa McPherson Trust ever existed or it was here in Clearwater. So, you know, it would be a real bad stretch to think that, you know, he’s working at the trust because

700

he’s picketing.

Q Well, is there a particular reason why the trust had that tape in its film library?

A Maybe someone videotaped it and gave it to the trust, Mr. Weinberg.

Q Well, who was the videotaper for the trust?

A Mark Bunker.
______________________________________

(WHEREUPON, the video was played.)

“Remember Lisa McPherson. Okay, let’s go. (Inaudible.)

“– is one of our old friends.

“Yes. Some other friends from Germany, too.

“That is a good one, too.

“Where else would you like –”

(Inaudible.)

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q Those are all people from the Lisa McPherson Trust, weren’t they?

A False.

Q Oh, Miss Caberta was from Germany, your guest over here?

A Ms. Caberta was here on vacation. Mrs. Caberta.

701

And if you will recall, you yourself earlier said she’s employed by the German government. So, you know, she’s not LMT. She’s just like you said, employed by the German government.

Q This was an LMT-sponsored picket in front of the Ft. Harrison Hotel?

A LMT has never, to my knowledge, sponsored a picket.

Q Is there a particular reason why Mr. Merrett was at that picket?

A I believe Mr. Merrett was at the picket to make sure that nothing happened, there were no altercations, no scuffles, no — you know, you’ll notice this, people, for the most part, are just silently walking up and down the street.

They are not screaming at Scientology itself or yelling at Scientologists; they are exercising their constitutional right to protest.

Q Do you think it might be somewhat harassing to the — on the doorstep of the mecca of Scientologists with signs saying “Blood of Lisa McPherson on your hands” and things like that?

A You know, I can see where someone could draw that inference or conclusion. But the inference and conclusion I draw is people were exercising their constitutional right.

If it was even a civil crime, they would have been sued out

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of existence.

Q Do you remember that the Lisa McPherson Trust — people documented by Lisa McPherson Trust video picketed in front of the Ft. Harrison Hotel when a Hindu wedding was going on? A Hindu wedding?

A No, I was not there. I know nothing about it.

Q As your position as the VP of the Lisa McPherson Trust, you don’t remember that one?

A Correct.

MR. WEINBERG: Why don’t we show that.

THE WITNESS: Was I present here?
______________________________________

(WHEREUPON, the video was played.)

“Well, Jesus, that is one thing Scientology didn’t believe in or any other religion, isn’t that right, guys? Isn’t that right? Isn’t that right? That is all — let’s let all of the Nazis come out.

“People are trying to have a wedding, sir.

“What is that?

“Hey, this is fine.

“They’re just trying to have a wedding. They are not —

“Listen, it’s not my fault they got married here.

“Come on now.

“This is a public sidewalk, buddy, so don’t start

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pushing.

“This is not — (inaudible).

“This is a public sidewalk. Let’s get out of the way. It is still a public sidewalk. Okay?

“When you get out of Scientology, your luck will — (Inaudible.)

“Let’s go. Let’s go.

“Let’s go.

“Come on.”

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q Why did the LMT put that in its film library?

A I think that every — and I’m not sure if this is not Mr. Mark Bunker’s film library that you are referring to — but, you know, we’re — we’re looking at here your two star witnesses. You are showing me videos of your witnesses that you have used in this hearing to testify for you. What are we doing here?

Q I think you said that this is the most harassed person you have ever seen. Does it look like Mr. Minton is the most harassed person you have ever seen when he’s standing there with a sign with skulls on it in front of the Ft. Harrison —

704

THE COURT: Don’t —

MR. WEINBERG: I’m sorry.

THE COURT: — raise your voice up to this witness and start approaching him.

MR. WEINBERG: I’m sorry.

THE COURT: I won’t have it. And I’m not going to remind you again.

BY MR. WEINBERG:

Q With a sign with skulls on it, interrupting a Hindu wedding?

A Mr. Weinberg, I agree with you what happened there — what happened was extremely inappropriate. And I don’t agree with it. And you didn’t see me there.

Q I’ll show you one you are at, Mr. Prince.

By the way, before you play that, that tape was done — the one we just played was done in — in September of 2000.

You were full-time at the Lisa McPherson Trust, correct?

A That is possible, yes.

Q Not possible. That is correct?

A I said it’s possible.

Q Why do you say it’s possible? I mean —

A Because I’m not sure when I made that transition from — I’ll explain it to you, I’m not trying to be coy

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here, but there came a point in time when my work with Mr. Dandar involved doing a bunch of depositions of Scientology staff members or Scientologists or whatever and we worked together quite a bit then.

But then there came a period of time when it was time for the medical experts. Those people are the experts. He certainly didn’t need me there. So there came a point in time when I started working at the Lisa McPherson Trust.

Q In September of 2000 when that took place, you were on the payroll of the Lisa McPherson Trust, correct?

A It is possible, yes.
______________________________________

(WHEREUPON, the video was played.)

“Jesse is — this is — Jesse, show him what you’re going to do if they come at you.

“Drop and fall. That is all. I’m going to fall down.

“Hey —

“You know what (inaudible).

“That is a good idea.

“Full resistance, that is our motto.

“How are you going to do it?

“Just carry the sign.

“Oh, my God.

“Kind of like the Three Stooges.

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“The St. Pete Police.

“Yes, I told them I would be there by quarter to seven.

“Oh, God.

“Let’s do this.

“Guys, remember what we all agree with. We’re all staying together.

“Yes, boss.

(Inaudible.)

“Uh-huh. Uh-huh. Okay, well — Mmm, no.”

(End of playing of the video tape.)
______________________________________

BY MR. WEINBERG:

Q Now, that is one of your six pickets?

A Rhetorical.

Q Excuse me?

A That is one of the six pickets I have probably been in.

Q And in that video we saw Patricia Greenway, correct, who is in the audience, right?

A Show it to me again. I missed that.

THE COURT: Yes, she was there.

THE WITNESS: Okay. I’ll take your word.

BY MR. WEINBERG:

Q Peter Alexander, who testified in this hearing?

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THE COURT: I don’t know if he was there or not.

MR. WEINBERG: He was.

THE COURT: I didn’t recognize him, but —

BY MR. WEINBERG:

Q The gentleman, sort of young guy in the pink or red shirt, that was Graham Berry, correct?

A Correct.

Q The lawyer from LA?

A Correct.

Q Now, your sign, “Mafia Cult”?

A Correct.

Q And that was —

A In relationship to the black operations that are run out of OSA.

Q And you were picketing, you walked from the LMT — this was an LMT operation, wasn’t it? That is where you-all left from, from the LMT?

A Yes.

Q And at that point, you were full-time at the LMT?

A I — I’ll stipulate to that, sure.

Q Except you were still working for Mr. Dandar, you were still doing stuff on the Lisa McPherson case, weren’t you?

A Well, you know, as I said, Mr. Weinberg, there
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came a time when Mr. Dandar was solely doing medical experts. There was certainly no need for me to sit there through that.

MR. WEINBERG: One second, your Honor.

BY MR. WEINBERG:

Q Now, you, Mr. Dandar and a number of other people from the LMT were at the closing when Mr. Minton closed on the purchase of the building either at the — at the beginning — January 5 of 2000, is that right?

A I believe that is correct.

Q And Mr. Dandar was — and you and Mr. Minton and Ms. Brooks were very enthusiastic about the LMT and how the LMT was going to — to operate. Correct?

A Yes.

Q And Ms. Liebreich was very enthusiastic about the LMT opening, correct?

A I don’t think Mrs. Liebreich was there.

Q But do you remember that the first phone call that was made was made to Ms. Liebreich, and you talked to her, among other people?

A I think I remember something about that, yes.

Q And she was very enthusiastic about that. Right?

A She was very happy and proud that the last wishes of Fannie McPherson were actually taking effect, which was to expose any deceptive and abusive processes by

709

Scientology, you know.

Mr. Minton is — just wants reform, tired of people calling, tired of people saying, “Can you please help.”

Q Your testimony, I believe, was — and correct me if I’m wrong — that you never met with Mr. Dandar for any purpose — for any meeting type purpose at the LMT. Is that right?

A Correct.

Q Now, do you remember at this opening that — at this closing where, in essence, the LMT was opening, that you described — or someone described what your position and responsibility was going to be at the LMT?

A I don’t recall it specifically, Mr. Weinberg.

Q And you deny it was in charge of PR, right?

A Correct.

MR. WEINBERG: If you could play that, please.

This is another video from the LMT.
______________________________________

(WHEREUPON, the video was played.)

“Ken, I’m sorry there’s no more chairs.

“It is okay.

“Sign first — (inaudible).

“You want to sit down? Here is the — these are the — (inaudible).

710

“Did you bring the property insurance papers?

“Of course not.

“You didn’t?

(Inaudible.)

“You mean the balance, it’s everything you did fax me yesterday.

(Inaudible).

“The insurance papers are the closing paper for the mortgage.

“Yeah. Right. Right.

(Inaudible.)

“That is okay. That is okay.

“It’s just that we don’t have the check for him — or, we have the check but — (inaudible).

“How are we going to do it? How are you going to do it?

(Inaudible.)

“No, I’ll just tell you to send a check and how much it is. (Inaudible.) It’s a binder.

(Inaudible.)

“If Scott has a fax machine I can fax it to him.

“Hang on one second. Okay?

“Yes.

“Okay.”

711
______________________________________

BY MR. WEINBERG:

Q Is that Tom Tobin from the St. Pete Times?

A I believe it is.
______________________________________

“This is Steve Mitchell. This is Jesse Prince.

“Nice to meet you, Jesse.

“Nice to meet you.

“He’s an expert on Scientology in the Lisa McPherson case. He’s going to be also working at the trust.

“Oh. Terrific.

(Inaudible.)

“So he has an idea of what we’re dealing with. Big time, right?

“Big time, Bobby. This is too cool.

“Jesse, what are you going to do with this organization?

“Make it as successful as possible.

“I mean, what’s your job or what — do you have functions or duties or —

“I’m on the board of directors. And I’m going to just, you know, be here with the organization, get it through its initial phase of establishing itself, and run around and do public relations.

“Oh, really.

712

“Yes.

“He’s also an expert on the Lisa McPherson case so he’s going to be spending a lot of time with Ken Dandar so he’ll be –”

(Inaudible.)

“He’s been working, you know, intimately with Ken on this case for a long time.

“Oh.

(Inaudible.)

“You mean, does he own the building now?

“Thank you very much. Thank you. Scott.

“Thank you.

“Thank you very much. I can’t tell you how much I appreciate this.

“I wish you the best. I hope you do well with this.

“Thank you.

“Scott’s been under a lot of pressure, I’m sure.

“Congratulations.

“Thank you.

“Jesse.

“Hey, Ken?

“Hey, Ken?

“So anybody want to open that champagne?

(Inaudible.)

713

“Ken, your comments?

“Well, I think this is a good day for downtown Clearwater.

“Hi, Mike. How is it going?

“Happy New Year.

“We just closed on the building.

“Okay. Call me.

“I have a binder in my office.”

(End of playing of the video tape.)
______________________________________

MR. DANDAR: Could we have a stipulation that was edited by the defense?

MR. WEINBERG: I mean —

THE COURT: I don’t know if it was or not.

MR. WEINBERG: I mean, Mr. Bunker edited a lot of these tapes before he ever gave them to us. I mean —

MR. DANDAR: Well, whatever.

MR. WEINBERG: I mean —

THE COURT: All I can say, Counselor, it is available for you to get a copy of, so —

MR. DANDAR: I know.

BY MR. WEINBERG:

Q Now, what was the Lisa McPherson trial consultant and the Lisa McPherson case lawyer doing at the closing of

714

the LMT building?

A It looks like they were partaking in the festivities, to me.

Q It does to me, too, Mr. Prince.

A Yeah.

Q Now, when Ms. Brooks said that you were going to be doing public relations, was your first job to get Tom Tobin from the St. Pete Times there?

A You know, I think that is a leap in logic. And I think the person that actually said doing public relations stuff was me. I don’t think it was Ms. Brooks.

Q All right, I stand corrected. When you said you were doing public relations, what did you mean?

A I think that that was just an offhand comment. And I didn’t even know what I meant. Maybe I had some intention on doing something public relations-wise.

But what factually ended up happening is once the door opened, the phones started ringing. And as I mentioned, you know, getting through the initial establishment part, to find out exactly what our role is going to be, it simply turned into servicing current and ex-Scientology members.

Q The way you got your message out was to carry signs and picket in front of the Church of Scientology?

A That was the one thing that was done.

715

Q And — but at this time when this started in January 5 of 2000, you were in charge of public relations but you were being paid by Mr. Dandar to be a so-called expert in the Lisa McPherson case. Correct?

A That is totally incorrect. There was no public relations. I was not doing public relations, orchestrating public relations, media contact.

Mr. Weinberg, if you have shown anything with the indiscretion I have used, public relations is not anything that I would even pretend to be versed in, so, you know, let’s move on.

THE COURT: I’m going to tolerate about one more of these, then I can’t stand any more for the day. I still do not know why we’re playing all of these, but —

MR. WEINBERG: I can explain.

THE COURT: I’ll let you do that in closing argument, but I can only stand one more today, so play it and —

MR. WEINBERG: I’ll play one more and it will be this one.

THE COURT: All right.

MR. WEINBERG: December 2, picket across from the Ft. Harrison.

I want you to look for Mr. Dandar here. All

716

right?

THE WITNESS: Okay. All right.

THE COURT: What is the date again, Counselor?

MR. WEINBERG: December 2, 2000.

THE WITNESS: Was I at this picket?

(WHEREUPON, the video was played. No audio available.)

BY MR. WEINBERG:

Q You recognize the person with the sign was Frank Oliver?

A Yes.

Q You recognize Teresa Summers? She testified in this case.

A Yes.

Q You recognize yourself?

A Yes.

Q You recognize Mr. Merrett?

A Yes.

Q You recognize Mr. Minton?

A Yes.

Q You recognize Mr. Dandar. Correct?

A Yes.

Q And that was in front of the Ft. Harrison during a picket, wasn’t it?

THE COURT: I didn’t see any signs except

717

one — I did not see what I would classify as a picket.

A There was no picket. And I remember this incident, if you’ll let me explain it to you.

Bob Minton had come into town and Ken needed to talk to him or see him for something. Mr. Dandar simply stopped by. Mr. Dandar was not a part of any picket or doing anything. He simply knew where Mr. Minton was going to be, he came there, spoke with him and left.

BY MR. WEINBERG:

Q So what were you-all doing there?

THE COURT: I saw folks across the street, Counsel, that had signs, then somebody said hi, went across the street. That is where Mr. Dandar was.

The sign was down. The only one person that had it, they were talking, then somebody put a sign up and went off like there was something else going on someplace else.

I don’t think it would be fair to classify what Mr. Dandar was in was a picket. I could not tell they were in front of any hotel, either.

BY MR. WEINBERG:

Q Well, you recognize that was across from the Ft. Harrison?

A No, I do not.

718

THE COURT: I don’t know where it was because I couldn’t tell. It looked like a street corner. It might have been. I don’t recognize that.

MR. DANDAR: I can tell you, Judge. It was catty-corner across the street from the Ft. Harrison. These people with signs who were across the street from me, across the street from the Ft. Harrison, were standing in front of the new Super Power building. But I wasn’t part of any picket.

That is right.

BY MR. WEINBERG:

Q Now, was Mr. Merrett part of the picket?

A No, he was not.

Q Were you?

A No, I was not.

Q So you had been — so all these LMT people were sort of off to the side, and there were other LMT people that were holding signs?

A You know, again, Counselor, I’m not trying to be difficult here. You are showing snippets and you are drawing conclusions. The conclusion that I see from this snippet is we are simply standing there having a conversation. No one but no one is picketing.

THE COURT: Looks like there was getting ready to be a picket. There were people with signs, but

719

when they saw Dandar, it looks like somebody waved, walked across the street, the guy that had the sign, whoever that was, the one, put his sign down. When he picked up the sign, he went walking off to where I would presume a picket was going on. But those other folks were across the street that must have been going for a picket, I’m guessing.

I, LYNNE J. IDE, Registered Merit Reporter, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.

Mr. Prince, you’re already under oath. So you understand that the oath that you took will be valid throughout your testimony.

THE WITNESS: Yes, I do.

THE COURT: All right. Would you please resume the stand?

Let me make sure, before we start, that I’ve got the right book.

Give me just a minute, Mr. Dandar.

0192

Hugh Haney? Was that the last witness?

MR. DANDAR: Brian —

THE COURT: Brian.

MR. DANDAR: Hugh Brian —

THE COURT: Brian.

MR. DANDAR: Hugh Brian Haney.

THE COURT: Okay. I wrote down Hugh. Hugh Brian?

MR. DANDAR: Yes. He goes by Brian.

THE COURT: Okay. All right. I’ve got the right book. I’m ready.

Mr. Bailiff, before we start, is this coffee — I mean — coffee — see, I was thinking of coffee. That’d be nice. Maybe you’ll bring me some. Is this water fresh?

THE BAILIFF: I’m not sure, your Honor.

MR. WEINBERG: I would say that would be —

MR. FUGATE: — a “no.”

THE COURT: That’s what I would say.

Would you mind?

No telling how long that’s been sitting in there. You know what he’ll do? It’ll have mold on it. He’ll go — pour it out — Thank you very much.

When this trial comes — because I will let you

0193

all have water during the trial. Not coffee, once we get to a trial —

MR. WEINBERG: Right.

THE COURT: — just water.

But I’m going to get me a little cooler and keep it up here. Because I don’t trust them — I can’t ask every day. Just one of the tiny little things that needs to be done.

And by the way, Mr. Dandar —

MR. DANDAR: Yes, Judge.

THE COURT: — if I might just suggest, I did notice in that article that you were quoted. The truth of the matter is, this is an ongoing case. It would be well for you not to be quoted in these articles.

MR. DANDAR: I do not believe that I or Mr. Prince gave an interview for that article.

THE COURT: Okay.

MR. DANDAR: I think — I think the reporter is quoting from in-court testimony.

THE COURT: If that’s the case, then we can’t help that.

But — but do not — and I’m not going to tell the lawyers how they ought to be lawyers, because you know, part of the — part of the canons say one

0194

ought not to be talking to the press about their case while it’s ongoing.

MR. DANDAR: Right.

THE COURT: That would be like you all having some comment for me. I don’t think you would be appreciative of that.

MR. DANDAR: I do —

That’s what happens to me — off the record?

Can we go off the record for just a second?

MR. LIEBERMAN: Yes.

MR. DANDAR: Yes.

THE COURT: Madam Reporter?

THE REPORTER: Yes, ma’am.

(A discussion was held off the record.)

THE COURT: All right. Back on the record.
___________________________________

BY MR. DANDAR:

Q All right. Mr. Prince, two weeks ago, we talked about your position with the Religious Technology Center; you getting these eyes-only reports on ongoing investigations involving litigation and other critics of Scientology.

A This is a document — a document written by L. Ron Hubbard concerning intelligence. And it speaks about predicting trouble before it occurs, investigating individuals for crimes, and prosecuting the individuals.

And this all has to do with people who Scientology perceives to be enemies or suppressive persons.

Q Against whom? They’re enemies of whom?

A These are perceived enemies of Scientology. These are the actions that are done against perceived enemies of Scientology.

Q On the — it’s a one-page document. The third paragraph talks about a standard, is to — when you’re under attack, you attack back. Does that have anything to do with the prior document where you — where it mentioned, and you explained to the judge two weeks ago, manufacturing evidence if there’s no crimes found?

MR. WEINBERG: Well, I object to all this, your Honor.

First of all, this is a 1968 thing.

Secondly, I just want to let the record be clear again as to our position about Mr. Prince interpreting policy. He was booted out of the church — booted out of the position in 1987; left in disgrace from the church; has been — has been —

0196

has been, you know, paid to testify against the church. And now he’s coming in here trying to interpret policies; one a 1968 thing that doesn’t say anything about creating or manufacturing evidence and saying that — trying to interpret it?

I — I object to that.

THE COURT: Overruled.

BY MR. DANDAR:

Q Does this policy have anything to do with the prior policy that you identified two weeks ago, and explained to the court about, if you can’t find the crimes of the attacker, you manufacture the crimes?

A Yes. This is part and parcel of the activities of the intelligence department in different Scientology organizations.

Q What does that mean in that third paragraph from the bottom, attack loudly?

A You know, I think we must be looking at a different — I must be looking at a different document than you.

Q I hope not.

A Where did you see that –Oh, I see, okay. Yes. Okay.

Q What does that mean, attack loudly?

A Noisy investigation.

0197

MR. WEINBERG: Excuse me, your Honor. What he’s saying is what it means to him?

THE COURT: Yes.

MR. WEINBERG: As opposed to what it means?

THE COURT: That’s what he’s saying.

BY MR. DANDAR:

Q Within your experience and your position of the inspector general RTC worldwide, tell us what that understanding — what you’re understanding of that means.

MR. WEINBERG: Well, see —

A This would mean —

MR. WEINBERG: That, I object to. If he wants to sit up there and say what it means to him, that’s one thing. If he wants to sit up there and say, “This is Jesse Prince and this is what this policy means to a Scientologist,” that’s nonsense. And that isn’t right.

And that’s what’s been going on for — for — you know, with Mr. Prince and Mr. Young and other people that used to be in the — in the church. It’s not right. They shouldn’t be up here trying to interpret for the — for the religion of Scientology, what policy is.

THE COURT: That’s not even your argument; that’s the argument of the First Amendment scholar.

0198

And I have let him preserve that argument —

MR. WEINBERG: I understand.

THE COURT: — and it is preserved. And your objection therefore is overruled.

MR. WEINBERG: Okay.

THE COURT: Because quite frankly, if I don’t agree with his position, this would be relevant to this, and it would be relevant probably to your counterclaim.

MR. LIEBERMAN: Your Honor, I guess that means I should be objecting to —

THE COURT: No. Because I’ve allowed you to preserve a continuing objection.

MR. LIEBERMAN: Right. I understand that, your Honor.

But the point is, from the First Amendment point of view, to even let this kind of testimony in creates an untenable position for the church. Because if we — if we merely preserve our position, then we’re put in the position of, do we have to counter it? To counter it, we would then have to engage in a process which we shouldn’t have to constitutionally, which would be incredibly burdensome on us and on the court.

Because in order to understand Scientology

0199

policies, you can’t take one and look at it in isolation, and have somebody who was not — who was — who was basically removed from his position —

THE COURT: Yes.

MR. LIEBERMAN: — by the church —

THE COURT: But he was there. And he was there. And he presumably was high up in the scale. And he presumably knew what was going on, whether he was removed or not.

I’ve therefore ruled he’s qualified.

If you want to withdraw your motion, saying there was no basis in fact or law, and it was a fraudulent claim to file this lawsuit, then I will agree with you.

You filed the motion in this hearing. I think it’s relevant, quite frankly, and I think no matter what your First Amendment argument is going to be, I’m going to allow it in for this hearing. It’s your motion. That’s why I said I think you’re going to have some distinctions that I’m going to be willing to draw for different things. You do whatever you want to do for this motion. I’ve allowed you to preserve it. Your objection is preserved. You can argue it. Quite frankly, you

0200

may lose that motion for this hearing, as long as you have filed the motion you have filed.

You’ve made your argument. I’m ready to move on.

This is not somebody who was not in the church. This is not some scholar outside. This is somebody who was there, who says, “This is what we did.”

MR. LIEBERMAN: I know, your Honor. And he also was — was removed —

THE COURT: Well, then —

MR. LIEBERMAN: — from his position —

THE COURT: — do it on cross examination.

MR. LIEBERMAN: — for not being a Scientology expert; for being the opposite of a Scientology expert by the authority that had the ability to determine who are — who is capable, who is proper to speak for Scientology.

THE COURT: You know, the only thing I can suggest is, by all the argument that I hear from you all about Jesse Prince, you must be really frightened of him.

You’ve made your point. We’re going to move on.

BY MR. DANDAR:

Q Now, Mr. Prince, this third paragraph, third

0201

paragraph on Exhibit 113 states,

“Even if you don’t have enough data to win the case, still attack loudly. Reason is, it is only those people that have crimes that will attack us, and they will soon back off for fear of being found out when attacked back.”

Is this considered a scripture of the Church of Scientology?

A During — during my tenure in Scientology, this document was not considered to be any type of scripture. This was a training material to train a person in intelligence activities as practiced in Scientology.

Q Okay. Now, before the objection, you were talking about — answering the question about if this relates to the noisy investigation when this document, in the third paragraph from the bottom, speaks of or uses the word “loudly.”

A Yeah.

Q And what is a noisy investigation?

A A noisy investigation — I believe we covered that the first day I gave testimony, and we actually submitted the document in the church. But it’s basically to go around and arouse the neighbors and the friends and associates of a person that Scientology perceives to be an enemy, and make allegations about the person that may or may not be true. And according

0202

to Scientology’s Manual of Justice, which is a further document, that gives the exact procedure by which you go through to terrorize someone through investigation, noisy investigation, investigating loudly is certainly a part of it.

MR. WEINBERG: Object to the use of the word “terrorism” or “terrorize.” I mean, that’s just —

THE COURT: I didn’t hear him say that. Did he say that?

MR. WEINBERG: That’s what he said.

MR. DANDAR: Use it to terrorize the person who is attacking the Church of Scientology.

THE COURT: Overruled. I’m not thinking of that as terrorism; I’m thinking of that as just simply a word.

MR. WEINBERG: Well, that’s fine. But I’m a little sensitive, after reading this article this morning, where — or yesterday morning, where Osama Bin Laden and David Miscavige were mentioned in the same sentence.

MR. DANDAR: Take that up with the St. Pete Times.

MR. WEINBERG: Well, no, I —

THE COURT: Well, that was mentioned by Mr. Minton.

0203

MR. WEINBERG: Who — who — let’s make it clear — is not our witness, and is a person that has — that has worked very closely with Mr. Dandar from — from the beginning of this lawsuit.

THE COURT: I hate to tell you this, Counselor, but he is your witness.

MR. WEINBERG: Well —

THE COURT: You called him.

MR. WEINBERG: — your Honor, that’s where we disagree. But I’m not here to argue with that.

THE COURT: No.

MR. WEINBERG: We disagree about that.

We called him as a witness.

THE COURT: You can disagree all you want. You called him as a witness. I did not declare him a hostile or adverse witness. It appeared as if he was able to respond to your questions without leading questions.

You called him in this hearing as your witness.

MR. WEINBERG: But that doesn’t mean that Mr. Minton is — Well —

THE COURT: It does seem to be a lot ado about nothing, doesn’t it?

I understand about the article. That was

0204

Mr. Minton who said —

MR. WEINBERG: My —

THE COURT: — that.

MR. WEINBERG: — objection had to do with Mr. Prince saying “terrorize,” which is — which is —

THE COURT: Well, your objection’s overruled.

He can use the word “terrorize” if that’s the word he wants to use. That has nothing to do, in my opinion, with a terrorist attack. “Terrorize” is just a word. We use it all the time. Don’t be so sensitive.

Golly, we’ve got to get down into getting back into — stop being so sensitive.

BY MR. DANDAR:

Q In your experience in — in RTC, in Scientology, how do you go about finding or manufacturing threats against the critics?

A Well, there’s several ways that I’ve — I’ve seen it done —

THE COURT: And I’m sorry. When I indicated about the —

Excuse me.

When I indicated about the motion to dismiss, what I also meant to say is that this is relevant to this hearing because of Mr. Minton and the

0205

allegations that Mr. Minton has been extorted for his testimony. So for that reason as well, I think it’s admissible in this hearing.

Forget what I said about — I — I haven’t gotten my head back into this case.

MR. WEINBERG: My head was doing fine until I read the paper yesterday and then I got all upset.

BY MR. DANDAR:

Q So —

THE COURT: I’m sorry, Mr. Prince. I interrupted you.

Madam Court Reporter, read back that question before I interrupted him.

THE REPORTER: The pending question is, “In your experience in RTC, in Scientology, how do you go about finding or manufacturing threats against the critics?”

The witness began to answer, “Well, there’s several ways that I’ve — I’ve seen it done –”

A Yes.

As far as out-and-out manufacturing information — And again, I want to clarify that. During the time that I was in RTC, the greater part of my history in Scientology certainly had to do with what it calls

0206

technology, which is the delivery of auditing and training of things.

Now, when I got in RTC, I began to learn about this other aspect of Scientology, which had been hidden from me until that point. So I — I actually had a very short amount of time there. But as what I’ve seen as far as manufacturing information to nullify a critic, a person — Rick Aznaran took a private investigator over to Taiwan to investigate a fellow named John Nelson. John Nelson used to be a person that was the CO — the commanding officer of Sea Org —

MR. WEINBERG: Objection.

A — International.

MR. WEINBERG: Hearsay, your Honor. How’s he know this?

THE WITNESS: Because I was there.

MR. WEINBERG: You were in Hong Kong?

THE WITNESS: No. I was on the phone with the parties.

THE COURT: I’m going to allow it.

BY MR. DANDAR:

Q Were you in charge of the parties?

A Yes. The party was working in one of my divisions.

At any rate, Rick Aznaran flew to Taiwan with a

0207

private investigator to investigate a fellow named John Nelson, who used to be in a very high position in Scientology. He was the commanding officer of CMO.

THE COURT: At what?

THE WITNESS: The commanding officer of the Commodores Messenger Organization.

BY MR. DANDAR:

Q And that was an elite organization?

A At the time, it was located at Gilman Hot Springs, which eventually became Church of Scientology International. CSI.

Q All right.

A And he had started his own splinter organization with another fellow named David Mayo. At any rate, he was perceived to be a great enemy by Scientology. So he was on a business trip in Taiwan. Rick Aznaran, along with the private investigator, rented a room next door to his, electronically bugged his room so that they would know when he was coming and going; and when he left, subsequently put heroin in his room. And the plan was to call the police when he came, to say he was a — a heroin dealer, to get him turned in for this heroin package.

I found out about that because the private investigator that was working with Mr. Aznaran called back to the United States. I was on the phone. He said, “Look,

0208

this is going down. Over here in Taiwan, if a person gets convicted as a heroin dealer, they get the death sentence.”

I was not going to be a party to anything like that; neither did the private investigator. He was coming back. I immediately informed my senior, who was Vicki Aznaran. We conferenced with Mr. Miscavige on the situation and immediately had Mr. Aznaran come back and be away — not to do that particular operation.

This was an instance of manufacturing information that I know of, that I was personally involved in and had personal knowledge of. I’ve heard other things about that.

And of course, that would be hearsay, as Mr. —

Q Well, what year was this?

A That this occurred?

Q Yes.

A This happened in 1985.

Q Okay. Okay. And in your position, though, at RTC, you would hear about many operations against critics or perceived enemies of Scientology, is that right?

A Perceived enemies of Scientology is a — is — is what would correctly define — as opposed to critics.Because there was — you know, critics wasn’t a word that we used in Scientology when I was there. “Oh, this person’s a critic.” That’s not a word that we would use in Scientology. We would use this person is a suppressive.

0209

This person is attacking Scientology. But it wasn’t — this whole critic thing didn’t come into being, I believe, until after I even left Scientology.

Q All right. Well, what about the enemies of Scientology? What other examples can you give us where you have personal knowledge as to the operations that were going on?

A The other partner of this fellow, his name was David Mayo. He was the actual author of the NOTS Materials, the NED for OTs. And he —

THE COURT: Of the what materials?

THE WITNESS: NED for OTs materials. This is the — this is the —

MR. DANDAR: NOTS.

THE WITNESS: In Scientology, this is OT4, 5, 6 and 7.

THE COURT: What does the N mean on the front of that?

THE WITNESS: New Era Dianetics for Operating Thetans. And it’s an acronym, NED.

MR. DANDAR: NED.

THE WITNESS: NED.

MR. WEINBERG: Your Honor, objection. No foundation for any of this testimony. I mean, that David Mayo wrote this? Based on what?

0210

THE COURT: I’m sorry. I didn’t understand. I thought he was talking about the NOTS. I’ve seen that in some of the literature.

MR. DANDAR: Yes. That’s what he was —

MR. WEINBERG: But what —

MR. DANDAR: — talking —

THE COURT: I just simply asked what it — what it meant.

MR. WEINBERG: No — all right.

But what he said before that was — that prompted your question — was that David Mayo had actually been the author of the NOTS Materials, OT, whatever it is.

MR. DANDAR: You know, this is great for cross examination, but it’s really interrupting the flow of the direct.

MR. WEINBERG: Excuse me.

There was an entire proceeding in California about all this.

THE COURT: Well, I’m going to allow it.

BY MR. DANDAR:

Q How do you know that David Mayo is the author of NOTS, since Mr. Weinberg wants to know?

A Because it’s — the NOTS Materials, as I saw them in 1985 — each and every one of them had his signature or

0211

his initials on each page of the issues of the various NED for OTs issues. I think at the time there was 55 of them. So 55 little signatures of David Mayo, who wrote these materials. This is what I base that opinion on.

Q And he was a Scientologist at the time he wrote them, correct?

A He was a senior CS international at the time he wrote that.

Q And he worked closely with Mr. Hubbard, correct?

A He was Mr. Hubbard’s auditor, correct.

Q All right. So what happened — what was the operation against Mr. Mayo?

A Well, he was the other partner of John Nelson.

And what was done to him was they had rented a place, a business place, office complex. They were on the first floor. Scientology PIs rented the office directly above his office and electronically bugged the downstairs area. Also, a fellow named Bob Mithoff, who is the brother of Ray Mithoff, who is the current senior CS Int —

(The reporter asked for clarification.)

THE WITNESS: I’m sorry.

A — was the current senior CS Int, sent in as a deep undercover operative, as well as Carolyn Letkerman, as well as Nancy Mainy.2

And the purpose of these deep cover operatives

0212

were to divine the legal strategies of the Advanced Abilities Center to provide information about financial accounts, how much money the place was making. They stole the mailing list for the place. It was turned over to the Religious Technology Center. And they were basically sent in there to not only glean information but to disrupt activities, covertly disrupt activities.

MR. WEINBERG: Your Honor, could we date this, and could Mr. Prince tell us what the basis — what his —

THE COURT: Yes. What was the year?

MR. WEINBERG: — of the information is?

THE WITNESS: This, I believe, was 1985. It was Wollersheim 4, where I actually testified in a hearing in front of Judge Mariana Phaelzer3 ultimately. And on March 15th — not March 15th, but somewhere around that time period. This all had to do with the Wollersheim case.

BY MR. DANDAR:

Q And when you testified in front of a judge on Wollersheim 4, who were you testifying for?

A Church of Scientology — Religious Technology Center.

THE COURT: You testified for the Religious Technology Center that the — that someone from the

0213

Church of Scientology went into —

THE WITNESS: No, no, no, your Honor.

THE COURT: — this man’s place and —

THE WITNESS: No. I —

THE COURT: — stole —

MR. DANDAR: Wait —

THE WITNESS: No.

THE COURT: — his mailing list and —

THE WITNESS: No, no. No. That’s not what I testified to.

What I testified to was the fact that the materials that were being used in the Advanced Abilities Center were identical, basically, to the ones that the church had owned and copyrighted.

THE COURT: I see. So he — this Mr. David Mayo was another person who kind of broke off and was in a splinter group.

THE WITNESS: Yes. He was — he was kicked out of Scientology.

As a matter of fact, I think I brought the document with me today that — that shows why he was kicked out of Scientology.

And when he left he started his own movement, basically.

THE COURT: Okay.

0214

BY MR. DANDAR:

Q What’s the name of that document?

THE COURT: Was he — was he —

A RTC Conditions Order Number 1.

THE COURT: Was he — was he with Mr. Nelson?

THE WITNESS: Yes.

THE COURT: They were part of the same splinter group?

THE WITNESS: Yes.

THE COURT: I see.

MR. DANDAR: Your Honor — I’ll tell you what —

MR. WEINBERG: Could we just have Mr. Prince say what the basis for his testimony was, whether it’s hearsay or did he give these alleged orders to — to —

THE COURT: Okay.

MR. WEINBERG: — break in and bug and —

THE COURT: How did you know about this?

THE WITNESS: I knew about this because the — the people that were doing the activities were in a division in RTC that I supervised.

THE COURT: Okay.

THE WITNESS: And the — the people that were involved — I can tell you specifically the names of

0215

this person. Gary Klinger, who was our intelligence officer in RTC.

THE COURT: Who was “our”? “Our”?

THE WITNESS: I’m sorry. RTC.

THE COURT: Okay.

THE WITNESS: Jeff Schriver.

THE COURT: So you were supervising the people who were doing this?

THE WITNESS: Yes, your Honor.

THE COURT: There’s your foundation. I mean, that’s the foundation.

MR. DANDAR: Judge, I only have — I haven’t copied this yet, but I want him to identify it. We have the copier in the jury room so it doesn’t cause any noise. And then we’ll copy it. But this is Plaintiff’s Exhibit 114.

THE COURT: Okay.

BY MR. DANDAR:

Q Can you identify that?

MR. DANDAR: Then we’ll have it copied.

A This is the first Religious Technology Center Conditions Order, which is a committee of evidence, actually. And it lists — one, two, three, four, five, six, 24 seven, eight, nine, 10, 11, 12, 13, 14, 15, 16 — has 16 individuals listed on this document, of people that are

0216

receiving a justice action. These are people that were once in management, in Scientology, prior to 9 October, 1982. So David Mayo here was the senior CS international. He’s on this document. And this is the document that lists all of their supposed and alleged crimes.

And the people that constituted the committee that would determine their guilt or innocence on this crime composed of — one, two, three, four, five, six — seven people.

And the chairman was Ray Mithoff. The secretary was Shelly Miscavige. That’s David Miscavige’s wife. A member was Laura Marlowe. Laura Marlowe was Commander Steve Marlowe’s wife, who — at the time, he was a commander of the Religious Technology Center. And then is myself, Jesse Prince. Then there’s Gelda Mithoff, who’s the wife of Ray Mithoff, and Matt Pesch and Mark Fisher. Matt Pesch was a security guard. Mark Fisher was a personal assistant to David Miscavige.

And this committee was charged with finding — and this was basically what is constituted all of in management — to, you know, basically do another housecleaning or purging, as has happened in Scientology a time or two.

MR. DANDAR: Judge, I’d like to go ahead and

0217

have this copied, and I’ll distribute it. Is that all right?

THE COURT: Sure.

Did you mark it?

MR. DANDAR: Yes. It’s 114.

MR. WEINBERG: I have an objection to relevance. I haven’t looked at it yet. But what’s the relevance of a 1982 —

THE COURT: I don’t know.

MR. WEINBERG: — religious justice action against people?

THE COURT: I can only assume that this is part of Mr. Dandar’s case regarding his allegations of threats, extortions or whatever it is he’s alleging about.

MR. WEINBERG: That may be. But Mr. Minton was never a Scientologist so Mr. Minton didn’t — didn’t — didn’t undergo any committee of evidence or Scientology justice action.

I just don’t understand the relevance.

THE COURT: What is the relevance?

THE WITNESS: Well —

THE COURT: No. Not you.

THE WITNESS: Oh.

MR. DANDAR: Mr. Prince, who Mr. Weinberg

0218

called a janitor, is on this committee of evidence, with the other top Int management people, on a committee of evidence against David Mayo, who is the author of this highly secretive NOTS material. And it just shows Mr. Prince’s involvement in the higher echelons of Scientology.

THE COURT: So this is — this is just to show that he’s got some — what, that is — that he — is — is capable of testifying as an expert here?

MR. DANDAR: Yes. And —

THE COURT: Well, I’ve already accepted him as an expert.

MR. DANDAR: Okay. But it also goes to the policy bulletin on intelligence actions, which he — which is the basis of this testimony before we reached that document.

THE COURT: All right. Then I suppose it may have some relevance. I don’t know.

MR. WEINBERG: How does it go to that?

THE COURT: I don’t know. I mean, I have to believe some of the things the lawyers say.

MR. DANDAR: Let me show our next exhibit.This is in a series of, like, three or four documents on this subject. And then we’ll get on to a different matter.

0219

BY MR. DANDAR:

Q Plaintiff’s Exhibit 115, Mr. Prince. Can you identify that?

A Yes. This is a confidential issue that goes along with intelligence actions, noisy investigation, the Manual of Justice and other issues that really gives the attitude of how to go about taking apart a perceived enemy. It kind of gives the thought process, the — the basis of it. It comes from Klausewitz.

Q Again, this is entitled Battle Tactics. This is directed against the enemies of Scientology?

A Correct.

Q And then the third — actually, the fourth paragraph from the bottom it states — states, quote, One cuts off enemy communications, funds, connections. This policy letter goes to — applies to former Scientologists as well as someone who’s an — an enemy, who has never been a Scientologist?

A It could be anyone Scientology perceives as a — as an enemy.

THE COURT: Is this again what you call a suppressive person?

THE WITNESS: Yes. Or a suppressive group.

THE COURT: Okay.

THE WITNESS: And this talks about cutting off

0220

enemy communications, funds, connections; deprive the enemy of political advantages, connections and power. He takes over enemy territory; he raids and harasses. All on a thought plane —

THE COURT: Okay. You don’t have to read it to me, Mr. Prince. I —

THE WITNESS: Okay.

THE COURT: — can read.

BY MR. DANDAR:

Q Mr. Prince, on page 2, the second paragraph states, “Legal is a slow if often final battle arena. It eventually comes down to legal in the end. If intelligence and PRO have done well, then legal gets an easy win, close quote. What is PRO?

A Public relations officer.

Q And intelligence is what?

A Intelligence is the intelligence branch or department or division of Scientology organizations. Intelligence having to do with the prediction. Again, it goes back to this issue we have here, intelligence actions. The purpose of intelligence is to predict trouble, basically, before it occurs. And it states that in the issue.

So intelligence would predict or would start filing, start indexing, start doing this overt data collection, covert data collection, amass as much

0221

information about the situation as possible, then proceed accordingly.

Q That’s the — does that include the use of the private investigators?

A Yes.

Q Okay. Let me show you Exhibit 116.

THE COURT: While you’re doing that, can you all tell me whether or not a document called Middle — well, it’s something filed by Middle District of Florida, Complaint for Copyright infringement, Courage Productions versus Stacy Brooks — is that an exhibit in this hearing?

MR. WEINBERG: I believe so.

THE COURT: Okay.

MR. DANDAR: Not anymore?

MR. LIROT: It wasn’t one of our exhibits.

MR. WEINBERG: No. It was one of our exhibits.

THE COURT: Okay. Petition to Define Scope of Accounting and to Require Expedited Accounting?

MR. WEINBERG: I don’t think that is.

THE COURT: Okay.

MR. WEINBERG: I think it was just the complaint.

THE COURT: Okay.

0222

BY MR. DANDAR:

Q Mr. Prince, what is 116?

A 116 is a document in the same vein of the documents we’ve been studying before. It’s the public investigation section. And this basically has to do with — “investigates attacking individual members and see the results of the investigation, get adequate legal and publicity.”

So this again is similar to what we’ve gone over here before.

Q So it’s in a series of the other exhibits on how to deal with perceived enemies of Scientology?

A Correct.

Q Let me show you Plaintiff’s Exhibit 117, entitled Attacks on Scientology. What is that?

A Again, same year, same type of policy letter. It talks about dealing with attacks on Scientology. “An attack on Scientology –” well, you know, the basic principle is, never agree with the attack on Scientology; attack the attacker. That kind of thing.

Q Now, these were written in the mid- to late ’60s.

Were they still in effect when you were in your management position at RTC?

A Very much so. And they’re still in effect today.

MR. WEINBERG: Excuse me. Objection, your

0223

Honor. Based on what?

THE COURT: Sustained.

BY MR. DANDAR:

Q And how do you know they’re still in effect today?

A Because of that time track that was submitted into this courtroom of specific things that have — that have occurred to Mr. Minton over a period of years; over specifically what has happened to me because of my involvement in this case and other cases.

MR. WEINBERG: Same objection. Lack of foundation.

THE COURT: I think that he might can draw that inference, but I suspect he can’t testify that that is in fact what’s happening today. But he can infer that, I think.

BY MR. DANDAR:

Q Now, Mr. Minton — Mr. Prince, have any of the — these policies come into play in the — Pinellas County in the past?

MR. WEINBERG: Based on his experience while he was in the church? Is that what you’re asking?

MR. DANDAR: Yes.

MR. WEINBERG: You mean while he was there?

MR. DANDAR: No. Based upon his experience.

MR. WEINBERG: Well, then, I object. Come into

0224

play in Pinellas County?

THE COURT: If he’s talking about what occurred to him? Is that what you’re —

MR. DANDAR: No. What occurred to non-Scientologists in Pinellas County, orchestrated by the Church of Scientology in the past years. Before Mr. Minton arrived on the scene.

MR. WEINBERG: Your Honor —

THE COURT: How does he know that?

MR. DANDAR: Well, let me just use these exhibits then. I can see if he can qualify to talk about them.

THE COURT: All right.

MR. DANDAR: I probably gave you the wrong exhibit, but — I withdraw the question. And I’m just going to go to another question. I had the wrong exhibit in my hand.

BY MR. DANDAR:

Q Mr. Prince, can you identify Plaintiff’s Exhibit 118?

A Yes. This is similar to RTC Conditions Order Number 1, in that it’s an ethics order that declare — one, two, three, four, five, six, seven, eight, nine, 10, 11 — 12 people to be suppressive persons.

0225

Q Paragraph numbered 4 says, “They are fair game.” What does this have to do with?

A Fair game?

Q Yeah. What’s this exhibit have to do with?

A This exhibit has to do with people that used some version of what Scientology perceived to be as upper-level materials and started some type of distribution of those materials, and for this they were labeled suppressive.

Q All right. And —

MR. WEINBERG: Your Honor, again, objection. What does this have to do with this case? If the Church of Scientology, within its internal structure, just like the Catholic church, declares somebody, in their language, a suppressive, you know, because they did something against the church; like, you know, attempt to — to take the — the scripture and change it — what’s that got to do with this hearing?

THE COURT: I think —

MR. WEINBERG: Has nothing to do with this hearing.

THE COURT: Well, it does have something to do with this hearing. And if you don’t understand it, then I’ll have to explain it to you.

MR. WEINBERG: All right.

0226

THE COURT: It is very clear that the assertion being made is that Mr. Minton was a suppressive person; that Mr. Minton was subject to all of these things, including finding out all of the crimes that he may have committed, and bring it to his attention. That is the allegation of extortion.

MR. WEINBERG: These are people that are Scientologists, that are being declared pursuant — at the time, 1968 — being declared pursuant to the Scientology religious practices, under their justice system. Mr. Minton’s not a Scientologist.

THE COURT: There’s no question in my mind that, according to the matters that have been brought to this hearing, that Mr. Minton would have been considered a suppressive person.

MR. WEINBERG: But he’s putting in a document that — that says pursuant to church policy, these Scientologists are — are getting a certain justice action. That’s what that is. I mean, he doesn’t have personal knowledge. This is 1968, before he ever was in the church.

THE COURT: But you remember that the testimony has been that when Mr. Hubbard wrote something, it was followed. And it wasn’t changed. And it would be a high crime to change the writings of

0227

Mr. Hubbard.

You know, we don’t change the Bible just because times change. I presume you don’t change the writings of Mr. Hubbard. I mean, that is about as clear as anything I know.

MR. WEINBERG: To suggest that — that there is only one interpretation —

THE COURT: Nobody said there was one —

MR. WEINBERG: — of 50 words that are written —

THE COURT: Nobody said there is one interpretation. This is something that —

MR. WEINBERG: — is preposterous.

THE COURT: — that Mr. Hubbard wrote.

MR. WEINBERG: That has to do with an internal justice action with regard to Scientologists, in 1968.

THE COURT: I see the relevance, Counselor.

Apparently you don’t. I do. It’s this hearing. I think it’s relevant to this hearing. And it’s coming in. Take it up. Make your objection. It’s made, take —

MR. WEINBERG: I understand.

THE COURT: — it to the appellate court. Do

0228

whatever you want to do. Your objection is overruled.

MR. WEINBERG: I understand.

BY MR. DANDAR:

Q Mr. Prince, is this document 118 strictly internal?

A This issue would have been published internally, but it would have gone out — but it’s something that would have been put in each organization so that they would know who these suppressive persons are. The purpose of these ethics orders — one of the purposes of these ethics orders is, when they’re issued, for everyone to have a copy, so that the same people couldn’t then walk into an organization and pretend to be Scientologists in good standing and — and wreak further havoc on the organization —

MR. WEINBERG: Your Honor —

A — if that’s what’s —

MR. WEINBERG: — that’s not —

A — Scientology —

MR. WEINBERG: — that’s not — objection.

(Simultaneous speakers.)

MR. WEINBERG: He cannot authenticate this document. I believe this document, for whatever it’s worth, is a forgery. But he can’t authenticate

0229

it. He’s just guessing. He’s speculating. He wasn’t there when it was published. If it was published.

BY MR. DANDAR:

Q Mr. Prince, how did you obtain this document?

THE COURT: Yeah. Where did you get it?

THE WITNESS: This document was provided to me by Vaughn Young.

THE COURT: So you did not receive this document or see this document when you were in the church.

THE WITNESS: No.

THE COURT: Then that objection is sustained and it will not be admitted.

BY MR. DANDAR:

Q Well, Mr. Prince, does this have the — does this appear to be a genuine document?

THE COURT: Well, that —

A Absolutely.

THE COURT: That isn’t going to get it. He can’t — he can’t authenticate something that was given to him by Mr. Young. I mean, this is not quite the same as some of these other things that I’ve seen — this is something called — I mean, I don’t know if this is authentic or not. Some of the

0230

other things that all look like the same, then I’m going to allow it in, necessarily, without his authenticating.

MR. DANDAR: All right.

THE COURT: But this is different. So 118 is out.

MR. DANDAR: Okay.

BY MR. DANDAR:

Q Let me show you Plaintiff’s Exhibit 119. Can you identify this, please?

A Yes. This is a policy letter dated 3 February, 1966, and it concerns illegal tax accounting and those activities within the Scientology organization.

Q You highlighted the first paragraph under the caption Illegal Officer? Why did you do that? A Because I think that it, again, just like these other issues that we’ve seen, goes along in the same vein, in that Scientology will do anything to protect itself, including what it says it’ll do here: Create the greatest possible confusion and loss to an individual, to a government or whoever to protect Scientology.

MR. DANDAR: Your Honor, I move Exhibits 113 through 117 into evidence, skipping over 118, and I move 119 into evidence.

THE COURT: I’m going to receive those.

0231

BY MR. DANDAR:

Q Now, Mr. Prince —

MR. FUGATE: Judge, I have an objection. And I know —

THE COURT: And I’m not going to hear from Mr. Weinberg and from you and from counsel from New York. I mean, there’s three lawyers at the table. It isn’t going to happen. So you sit down.

Mr. Weinberg’s making the objections. Or Mr. Weinberg, you defer to Mr. Fugate? Which is it going to be?

MR. FUGATE: Mr. Weinberg’s witness, your Honor.

THE COURT: All right. Thank you.

Occasionally I will hear from our First Amendment expert, occasionally.

BY MR. DANDAR:

Q Let me show you —

MR. LIEBERMAN: I’ll exercise restraint, your Honor.

THE COURT: Thank you.

MR. LIEBERMAN: But there are times when —

THE COURT: I’m sure.

MR. LIEBERMAN: — I may try —

0232

BY MR. DANDAR:

Q Plaintiff’s Exhibit 120, Mr. Prince?

A Yes.

Q Can you identify that?

A Yes.

THE COURT: Please remember this is a most unusual hearing that we’re having.

A This is a document that explains — a confidential document written by someone in the Guardian’s Office, which was the predecessor of the Office of Special Affairs, concerning — the mayor, Gabe Cazares.

MR. WEINBERG: Objection.

BY MR. DANDAR:

Q Of course, Mr. Cazares wasn’t a Scientologist, right?

A Correct.

Q So these actions — do the actions we just previously introduced into evidence have anything to do with the actions taken by the Church of Scientology against Mayor Cazares?

MR. WEINBERG: Objection, your Honor. He has no — he has no knowledge — he was never in the Guardian’s Office. We’ve heard a lot of testimony about the Guardian’s Office, all of which is that Mr. Miscavige came in and eliminated it because of

0233

its misconduct. This is a 1976 document. There’s no way he can authenticate it. God knows where he got this one and who gave it to him.

THE COURT: Where did you get this?

THE WITNESS: Your Honor, this was, I believe, on our Internet site — not ours — on the Lisa McPherson Trust Internet site.

THE COURT: And —

BY MR. DANDAR:

Q Is this from the evidence in the Washington, D.C. prosecution?

A Yes.

THE COURT: What Washington, D.C. prosecution?

THE WITNESS: This was — I believe this was an exhibit in the D.C. case —

MR. DANDAR: Mary —

THE WITNESS: — where the 11 defendants were —

MR. DANDAR: The Mary Sue Hubbard case, the Guardian’s Office; people who broke into the FBI and other public government buildings and were prosecuted. Mr. Franks talked about this —

MR. WEINBERG: So —

THE COURT: Excuse me.

0234

MR. WEINBERG: Your Honor, Mr. Dandar likes to throw allegations around. One that he did throw around was David Miscavige murdered or caused the murder of Lisa McPherson, which he has not addressed, and he needs to address it. But this Guardian’s Office stuff has nothing to do with this hearing. Nothing. They were — they were — whatever they did wasn’t authorized by Mr. Hubbard, wasn’t authorized by the Church of Scientology. It was found out, they were thrown out of the church and they were prosecuted. And that was all long before 1995. And what they were doing before Mr. Prince even got into Scientology. And he said he didn’t have anything to do with it.

THE COURT: This was — yeah. What is the relevance of this? It is true that the guardian ad litem — guardian ad litem. I need to get back to thinking — The Guardian’s office was — but I think that there’s been testimony that the Guardian’s Office was simply supplanted by another office. And I’ve forgotten the name of it.

THE WITNESS: Office of —

MR. DANDAR: Office of —

0235

THE WITNESS: — Special Affairs.

MR. DANDAR: — Special Affairs.

THE COURT: Office of Special Affairs.

THE WITNESS: Yes.

MR. DANDAR: It’s the same —

THE COURT: And consequently — there is testimony that it was the same — and it was just — it was just something that was done to — I don’t know if this is true, because — I mean, this is — I think there’s sufficient information to allow this in.

MR. WEINBERG: It’s not true. And Mr. Prince wasn’t in the Office of Special Affairs. He wasn’t, and he doesn’t have any — he is not competent to testify about what went on in the Office of Special Affairs. He certainly can’t testify about what went on in the Guardian’s Office because he wasn’t even — he wasn’t there, and he wasn’t in the church at the time.

THE COURT: Well —

MR. WEINBERG: I mean, this is just — it’s just like we’re just going to throw all of the slime we can — excuse me, Ken — we’re going to throw all the slime we can out here? Well, why don’t we —

THE COURT: Well, you know —

0236

MR. WEINBERG: — address —

THE COURT: — it’s your motion. If you want to withdraw it, then you’re not going to have any slime.

MR. WEINBERG: We’re not —

THE COURT: Withdraw —

MR. WEINBERG: — going to —

THE COURT: — or —

MR. WEINBERG: We’re not going —

THE COURT: — listen and make your objection and I’ll rule on it. And sit down. Now. I’m going to rule this is admissible.

MR. WEINBERG: All right.

THE COURT: You’re going to hear some slime when you throw out the kind of motion that you made.

MR. WEINBERG: Well, I understand that, but we’ve been hearing it for a long time.

THE COURT: Well, we’re going to hear it for a lot longer. You’ve had your turn. This is his turn.

BY MR. DANDAR:

Q What’s the significance of 120; Exhibit 120?

A Exhibit 120 here just kind of shows a pattern of conduct where —

THE COURT: I’m not sure that he needs to

0237

explain this to us.

What — was he in the office in 1976, in the church?

MR. DANDAR: No.

BY MR. DANDAR:

Q Were you in the church at that time?

THE COURT: Well, then —

A Yes —

THE COURT: — how does he know about —

A — I was —

THE COURT: — that?

THE WITNESS: Excuse me.

A But yes, I was in Scientology in ’76.

THE COURT: Then did this come up when you were with RTC or something like that?

THE WITNESS: Well, your Honor, I think the reason why we have this document in here is because it shows the pattern of conduct that is a continuing pattern of conduct, where if there’s a perceived enemy, such as Gabe Cazares, they wrote up a specific program to remove him from any position. That’s the first thing it says in this document, you know, to remove this person from his job so that he’s not a threat to Scientology. And — and it goes on where, you know, they had

0238

some college — the person pretend to be a college student and write a letter —

THE COURT: Well —

THE WITNESS: — saying —

THE COURT: — this is 2002. The allegation that this occurred is in the year 2002.

Do we have any thought that was — what was going on in 1976 is still going on or was going in 2002 with Mr. Minton? I mean, it’s farfetched.

THE WITNESS: Well —

THE COURT: As I said, I let it in, but I don’t need a whole bunch of —

THE WITNESS: Okay.

THE COURT: — explanation from Mr. Prince.

BY MR. DANDAR:

Q Well, let’s — we’ll quickly then look at 121, and then we’re finished with this part.

A Okay.

THE COURT: And by the way, you call it slime. I should not have used that word. That was your word. Very poor choice of my words.

MR. WEINBERG: It was my word.

THE COURT: Yes, it was.

MR. WEINBERG: And I never —

THE COURT: Okay. I don’t even know what it

0239

says. I haven’t read it. So I don’t know if it’s slime or not.

BY MR. DANDAR:

Q Mr. Prince, can you identify Plaintiff’s Exhibit 121?

A Yes. This is a document called Project Normandy. This was a project that was executed when Scientology first arrived in Clearwater, which describes an intelligence activity so that it would be informed of exactly —

MR. WEINBERG: Objection, your Honor. No competence. There’s no way he can authenticate this document.

THE COURT: Yeah. This document doesn’t look like any document that I have seen. How do you — where did you see this document?

THE WITNESS: There’s a — this — this document, the first copy that I saw, was on a long sheet of paper, and it had an exhibit — an exhibit stamp on it, because this is one of the documents that was taken from the 1977 raid in Los Angeles. As — in this current form, it doesn’t have it. This was something that’s on — that was on the Lisa McPherson Trust Web site.

THE COURT: So you’ve never seen this document except on the Web site?

0240

THE WITNESS: No. I — I have seen the document with the exhibit number on it. The exhibit number was put on it by a court in D.C. It was part 4 of the documents — stipulation of evidence that was turned in in D.C.

MR. DANDAR: There was a stipulation of evidence between the government prosecutor and the Church of Scientology.

MR. WEINBERG: How does he know? I mean, your Honor, he — Mr. Dandar’s testifying about some case that went on 20 years ago.

THE COURT: Well, I suppose he knows because presumably he’s done some homework on it. I don’t know.

MR. WEINBERG: Well, your Honor, there is no exhibit —

THE COURT: I’m not allowing this in.

MR. DANDAR: All right.

THE COURT: I’m not allowing it in because there’s nothing that tells me it can be authenticated by this witness.

MR. DANDAR: All right.

THE COURT: And we — I’m not going to let the Lisa McPherson Web site be the basis upon which anything is authenticated.

0241

BY MR. DANDAR:

Q Let me show you Plaintiff’s Exhibit 122.

THE COURT: How much of this are we going to have to go through?

MR. DANDAR: It’s the last —

THE COURT: Your point’s been made, I think, the point you’re trying to make.

MR. DANDAR: Last one.

THE COURT: Well, you just said that about Number 121.

MR. DANDAR: Well, you didn’t let it in, so — I’m just kidding. I’m just kidding.

BY MR. DANDAR:

Q Can you identify 122, Mr. Prince?

A Yes. Number 22 (sic) is a document written and copyrighted by Scientology, written by L. Ron Hubbard. It was intended, when it was written, for persons that worked in the 1st Division of Scientology —

And this basically outlined again how to deal with bad press, how to investigate an attacker, this kind of thing. And public relations; how to deal with the press and public relations.

MR. DANDAR: I move 122 into evidence.

THE COURT: Any objection?

MR. WEINBERG: No.

Only as to relevance. This has to do with internal justice actions —

THE COURT: Well —

MR. WEINBERG: — with regard to Scientologists.

THE COURT: If it can be authenticated —

MR. WEINBERG: I didn’t object to the authentication.

THE COURT: All right. It will be admitted for any relevance that it might have. May not have any. It’s just hard for me to — when documents are presented, to take the time out to read them. It may not have any relevance. And some of these — these things that I’m letting in may be absolutely irrelevant, but they’re long and they’re hard — and it’s hard to read them.

MR. WEINBERG: I understand. I mean, this church, like the Catholic church and a lot of

0243

churches, has internal — has an internal justice system where they deal internally with — with what —

THE COURT: Well —

MR. WEINBERG: — you know, what they call crimes but, you know, in the secular world, are not necessarily crimes. And —

THE COURT: And you can make — and you can certainly make that point in your closing argument.

MR. DANDAR: I would object to any reference to similarities with the Catholic church.

THE COURT: Well, you can object all you want.

MR. DANDAR: Thank you.

THE COURT: It’s been declared a religion. It is a religion. So is the Catholic church a religion.

BY MR. DANDAR:

Q Mr. Prince, is there anything in particular on this Exhibit 122 that you want to bring to the court’s attention?

A Well, if you turn to the second page, under the Investigations section, second paragraph, it says, “When we need somebody haunted, we investigate.”

This talks about not only people inside of Scientology; this is referring to individuals outside of

0244

Scientology; people that have never been Scientologists; people that are perceived enemies of Scientology. They don’t have to be a Scientologist. And it — and it — this is — this document itself explains the basis of intelligence, investigation, how it’s used, how you handle bad press. And it — it’s just kind of like a little handbook or a blueprint to the persons whose job it is to have that function within Scientology.

THE COURT: All right.

BY MR. DANDAR:

Q All right. Now —

THE COURT: Number 122 is in evidence.

BY MR. DANDAR:

Q Have you ever been the subject of a Scientology intelligence operation, Mr. Prince?

A Yes, I have.

Q What and when?

A I guess it was 1999. I used to do work with families that would call, that had — members within the Church of Scientology. And they were concerned, they wanted another opinion, a different viewpoint presented to their family member. I was called by a fellow named John Porter, who informed me about a fellow in Bakersfield, Las Vegas, Nevada — Bakersfield, Nevada, who had a son in Scientology.

0245

He had spend $200,000 within a month, and the family was concerned that he was squandering his inheritance. I flew to Vegas, met with the person who supposedly was the father, and we had a chat and were going to proceed with it. But as it turned out the person, John Porter, was a person hired — a Scientology-hired private investigator.

The person that posed as the victim’s father was a retired sheriff. And I guess the purpose — and you know, they paid me a thousand dollars to come down and do this. But I guess the purpose was to see if I was going to say or do anything criminal that could be used to show that I’m forcefully deprogramming or capturing people. And of course, that never happened, so — And then this — I’ve only recently learned that this even was so. The whole deal with having a black private investigator come, give me marijuana, come to my house, putting the seeds on the back porch — you know, I’m wondering, “Where is this,” you know, and I’m throwing it all — that whole stuff, as later come out, was an operation. I mean, they — they — My father lives in a retirement community. He’s 74 years old. The Scientologists have come and picketed his house and circled his house with signs.

0246

You know, those are just some of the things that have happened.

Q Okay. All right. Now, let’s go to Mr. Minton.

By the way, before we get to Minton, one question. You said you testified in the Wollersheim 4 case for the Church of Scientology Religious Technology Center. Did you ever testify in any other case for the Church of Scientology?

THE COURT: What year was that, please, Mr. Prince?

THE WITNESS: Your Honor, I believe it was 1986.

THE COURT: Were you still in the Church of Scientology at the time?

THE WITNESS: Yes.

THE COURT: And you testified as an expert for the church?

THE WITNESS: I testified as to — an expert particularly in the NED for OTs material.

THE COURT: See, he keeps saying that. I don’t know what that —

THE WITNESS: Oh.

THE COURT: Nefrotease (phonetic)?

THE WITNESS: NED for OTs.

MR. DANDAR: F-o-r.

0247

THE WITNESS: For. NED for OTs.

THE COURT: Oh. Sounds like you’re saying nefrotease.

THE WITNESS: Oh.

THE COURT: NED for OTs.

THE WITNESS: NED for OTs.

THE COURT: Okay.

THE WITNESS: I was a person qualified to study those documents, so I did a comparison to what David Mayo had as opposed to what the church had copyrighted, and I gave testimony about that.

THE COURT: So Madam Court Reporter, you understand all this time he’s been saying that, it’s NED for OTs?

THE REPORTER: Yes, your Honor.

THE COURT: Not “nefrotease.” All right.

(A discussion was held off the record.)

MR. DANDAR: And it’s abbreviated as NOTS.

THE COURT: So you were called to say, what, that this NED for OTs material was —

THE WITNESS: Was virtually identical to —

THE COURT: To some L. Ron Hubbard material.

THE WITNESS: No. The NED for OTs is the L. Ron Hubbard material. I was comparing them to similar materials that they were using at what was

0248

known as the Advanced Abilities Center.

MR. WEINBERG: Your Honor, just for the record, my — my understanding is that Mr. Prince was testifying as a fact witness, not as an expert witness.

THE COURT: Well, it does seem as if there’s some complications as to who’s a fact witness and who’s an expert witness, and that’s something we’ll have to wrestle with in this trial too. So we’ll not go there. We’ll say he was either a fact or an expert witness.

BY MR. DANDAR:

Q And you were — you were always — when you — before you were told — you didn’t choose Mr. Miscavige as being a leader and you were booted out onto the rehabilitation project force, were you considered, before that point in time, an expert on the tech of Scientology?

A Very much so.

Q Okay. I don’t think your microphone’s on.

A Oh. How about now?

Q No. I don’t think it’s turned on.

A Oh.

THE COURT: I can hear him fine. If you lawyers can hear him, okay.

0249

BY MR. DANDAR:

Q Now, is there a — how does Scientology consider a Scientologist coming into a courtroom or anywhere and talking about Scientology?

MR. WEINBERG: Well —

THE COURT: I’m sorry. What was the question?

BY MR. DANDAR:

Q How does the Church of Scientology consider someone who testifies or talks about Scientology?

MR. WEINBERG: Objection. He’s now speaking for the entire Church of Scientology now?

THE COURT: I don’t know.

A Well —

BY MR. DANDAR:

Q Pursuant to the — pursuant to written policy of the Church of Scientology.

A According —

MR. WEINBERG: We —

A — to —

MR. WEINBERG: We object. He is certainly not talking for the Church of Scientology as to how the church considers some Scientologist coming in and testifying.

THE COURT: If he is testifying regarding his experience when he was in the church and as a

0250

witness, I will allow it. He is testifying, however, based on that and not — he really wouldn’t know how everybody else thinks.

MR. DANDAR: No. It’s based on the former.

Right.

THE COURT: Right.

A It is written policy in the Scientology ethics book, in its management series and basic staff books, that it is a crime to come into a court and testify about Scientology without first going over the information with Scientology or ethics officer, somebody within Scientology.

In other words, it’s a crime to just walk into a courtroom and speak, give testimony about Scientology, without first Scientology being privy to what that’s going to be —

MR. WEINBERG: Well, could we — could he tell us where this policy is?

THE COURT: Right.

THE WITNESS: Introduction to Scientology Ethics. It’s right there. I can pull it out and read it for you.

THE WITNESS: Here’s one reference to that. It says, “Testifying hostilely before a state –”

THE COURT: Why don’t you give us a page number?

THE WITNESS: Oh, I’m sorry. This is page number 209.

THE COURT: Okay.

THE WITNESS: It’s listed under Suppressive Act. Suppressive Acts. And it says, “Testifying hostilely before state or public inquiries into Scientology to suppress it –”

THE COURT: Well, that doesn’t really say –what you had just testified to is that it was a crime to testify without first discussing —

THE WITNESS: Right.

THE COURT: — it with an ethics officer.

THE WITNESS: Yeah. You’re right.

And what I’m looking for is called —

THE COURT: I’ll tell you what we’ll do. Let’s just let him look for that either over the break, our morning break, or at lunch. And if he can’t find it, you can make your objection. And if he

0252

can, then he can cite it into the record at that time and we can just go ahead and move on.

THE WITNESS: Yeah.

THE COURT: So you keep that with you and you can —

MR. WEINBERG: We have no problem with bringing the whole book into evidence. I mean, the book — many of the policies in there are — we were probably going to — are completely contradictory to what Mr. Dandar’s witnesses have been saying.

THE COURT: Okay. Well, if you want to —

MR. WEINBERG: So —

THE COURT: — put it in — this may be Mr. Dandar’s only copy. So if you want to put it in, maybe you have an extra one and you can do that.

MR. WEINBERG: Okay.

BY MR. DANDAR:

Q Mr. Prince, have you heard the term “acceptable truth”?

A Yes.

Q In Scientology policy, what does that mean?

A An acceptable truth is basically a truth where you don’t have to tell the — tell the whole truth or to tell an accurate truth, but just tell the truth that would be acceptable to the person that you’re speaking to.

0253

Q Okay. Does it have anything to do with not telling the truth?

A Very much so. It’s a way to evade or avoid a question or to avoid — yeah — to — a direct question.

MR. WEINBERG: Could we ask Mr. Prince to identify the policy and show us where in the policy it says what he just said?

THE COURT: I think — I think there’s some stuff in evidence already on acceptable truth.

MR. WEINBERG: There is, but it doesn’t say what he just said, that it’s okay to lie.

THE COURT: Well, then it — I presume, Mr. Prince, whatever it is you’re talking about, is the document that I think I’ve already seen —

THE WITNESS: Yes, your Honor.

THE COURT: — acceptable truth?

MR. LIEBERMAN: Yes.

THE COURT: So this is your interpretation of it based on your years in the church?

THE WITNESS: Yes, your Honor.

THE COURT: I can’t — I can’t remember what number it is, but there is some number in evidence that deals with acceptable truth.

MR. DANDAR: It’s — it’s called a PR series,

0254

and it talks about PR, public relations, and the second page mentions acceptable truths. And I’ll find that for you during the break.

BY MR. DANDAR:

Q All right, Mr. — Mr. Prince. When is the first time you met Bob Minton?

A I met Bob Minton in 1998. I think it was the spring of 1998 or perhaps — no, perhaps it was the summer of 1998.

Q And how was it that you came to meet him?

A I met him through Mrs. Brooks. She introduced me to him.

Q Where at?

A New Hampshire. At his home in New Hampshire.

Q And what caused you to be at his home in New Hampshire?

A I was on vacation —

Well, this is kind of a long story. I was on vacation in Connecticut. Previous to that, I had seen the Internet. And I never knew anything about it, and I just typed in, “Hey, my name is Jesse Prince. If anyone sees Stacy or Vaughn, you know, have them contact me. Here’s my number.” So I was vacationing in Connecticut.

Stacy called me, and we met and talked, and she introduced me to Bob.

0255

Q Why is it that you went on the Internet for the first time and asked for — have Stacy Vaughn — Stacy Young or Vaughn Young call you?

A Well, this was 1998. I had literally no contact with computers after leaving Scientology, in a way that there would be messaging systems amongst organizations and people and things like that. I was — I didn’t know anything about the Internet. I was at a cafe, a cybercafe.

And I did a search and typed in Scientology, and saw all of this stuff come up about Scientology. I saw all of these people openly critical of Scientology.

Now, for me this was completely unheard of. Because if a person was critical of Scientology, they would quickly be silenced. And I saw that — that Stacy and Vaughn were saying something, or someone made reference to them.

So I answered their message as best that I could, and say, “I need these people to contact me.”

Q When was the last time you considered yourself a Scientologist?

A You know, I know I’ve answered the question in different ways. And the fact of the matter is, is it’s kind of hard to tell. I — for me, I think probably by 1996, maybe, I was kind of like pretty much completely done with anything about it.

Q You left the — you left the organization where

0256

you — from RTC, then RPF, and — and you went to work for a Scientology-run public company or a private company run by a Scientologist, correct?

A Correct.

Q And they practiced the Hubbard technology at that company?

A Correct.

Q All right. So were you a Scientologist, then, when you were working for that company?

A You know, part of it, yes; part of it, no.

Q Okay. When did you leave that company?

A I left that company, I believe, in 1997.

Q Okay. When did you get contacted by Earle Cooley, the attorney for the Church of Scientology, after you left, formally, your position in Scientology?

THE COURT: Well, let me help myself out here, ’cause I don’t know — When you left, whatever that is, were you still a member of the Sea Org?

THE WITNESS: No, your Honor.

THE COURT: Okay. When did you stop being a member of the Sea Org?

THE WITNESS: October 31st, 1992.

THE COURT: Okay.

MR. WEINBERG: Well, that is the answer to your

0257

question. That’s when he left.

THE COURT: Well, that’s —

MR. WEINBERG: So — so when he left — the day he left, he stopped being a member of the Sea Org, is what he’s telling you, I think.

THE WITNESS: Correct.

THE COURT: So why is it, from 1992 to 1996, that you still — you were — You’re saying you were like a public member? Is that it?

THE WITNESS: Just a Scientologist. Correct.

THE COURT: Just a Scientologist. Okay.

BY MR. DANDAR:

Q Judge just brought up something.

When — how — what is the — what do the Sea Org people call Scientologists who are not on staff, but they’re Scientologists?

A Public Scientologists.

Q So they use the word “public.”

A Correct.

Q Okay. After meeting with Mr. Minton in the summer of ’98, what did you do after that, in reference to Mr. Minton?

A I went back home to Minneapolis. At the time, I was living in Minneapolis. And I continued to have dialogue

0258

with Mrs. Brooks, who informed me about a lawsuit that Scientology had filed against a corporation called FACTNet. And we started to —

THE COURT: What was the date, now?

I’m sorry, Mr. Prince.

THE WITNESS: This would have been 1998.

THE COURT: Okay. This was after you went to Mr. Minton’s home in New Hampshire? You stayed in touch? Is what you’re —

THE WITNESS: Yes.

THE COURT: Okay.

THE WITNESS: Yes, your Honor.

A She said — she talked to me about that, and she put me in touch with Daniel Leipold. And I started looking over some of the issues, and thought that I could help. So I started talking with Daniel Leipold, Mrs. Brooks. And within a week I received a letter from a Scientology attorney, Elliott Abelson4, letting me know that I was going to be sued if I cooperated with anyone against Scientology, basically.

BY MR. DANDAR:

Q Based on what?

A Based on — well, for me to leave the situation that I was in in the Sea Org, I had to — it was a kind of a give-or-take thing. I had to make certain concessions.

0259

I was being held there against my will, as well as my wife. We were, you know, deprived of basic human needs and — for months. And we were told that if we signed these documents, we would be allowed to walk out the door. Again, this went on for months. And then finally, in October, whatever they wanted us to sign —

THE COURT: Of what year?

You see, everything —

THE WITNESS: October of 1992.

A Whatever they wanted us to sign, we signed. So he made reference to the fact that I had signed a document saying I wouldn’t assist anyone in bringing any legal action against Scientology, nor would I do it myself.

BY MR. DANDAR:

Q FACTNet wasn’t bringing legal action; they were being sued by Scientology.

A Correct.

THE COURT: Who was this lawyer again? Which lawyer?

THE WITNESS: Elliott Abelson.

BY MR. DANDAR:

Q And so when you started to meet with Mr. Leipold on the FACTNet case, you got this letter from Mr. Abelson. What did you do?

0260

A Well, I took it to the lawyer, and I explained the situation to him then, Daniel Leipold. And when I explained the situation to him, he actually drafted a suit against maybe Golden Era or whatever — I never actually saw the suit myself — and filed it in Riverside County. And then there was a whole press thing. I was interviewed by the newspaper and on and on.

Q Okay. Anything come out of that lawsuit?

A No.

Q All right. So did you go to work for FACTNet?

A Yes, I did.

Q All right. And how long did you stay there?

A Maybe about a year, a year and a half.

Q Okay. ’98 to ’99?

A ’98 to ’99. Yeah. About a year.

Q Okay. And at some point in time you came to Florida to look at the Lisa McPherson PC folders?

A Correct.

Q All right. And you looked over those folders with Stacy Brooks?

A Yes, I did.

Q And then after we received a copy of the PC folders under court order, you went and took your time and examined all —

MR. WEINBERG: Your Honor, could there be

0261

direct questions and not —

THE COURT: Yes.

MR. DANDAR: I’m just trying to speed it up.

MR. WEINBERG: Well, I would prefer a direct question.

THE COURT: Okay. Well, you know what, some of this — you’re right. But some of this is preliminary. We know he looked at the folders.

MR. WEINBERG: It’s the — it’s the testimony.

THE COURT: Okay.

MR. WEINBERG: I know he looked at them, and I didn’t object to that part of it.

THE COURT: Okay.

(A discussion was held off the record.)

THE COURT: We’ll take a break right now.

We’ll be in recess for 15 minutes or 20 minutes. 15, we’ll try for.

(A recess was taken at 10:48 a.m.)

(The proceedings resumed at 11:18 a.m.)

MR. BATTAGLIA: Your Honor, may I approach the bench?

THE COURT: You may.

MR. BATTAGLIA: I’d like to announce to the court I’m going to be making an appearance in this matter for Robert Minton as lead counsel, so I will

0262

be submitting a formal notice. I just want the court to be aware of that.

THE COURT: Now, will that be for all purposes?

MR. BATTAGLIA: Well, for all purposes. But Mr. Howie still will be involved in portions of the case.

We will send in a formal notice. We were retained this past Thursday.

THE COURT: All right. Very good. I think, Mr. Battaglia, there is a matter pending that I frankly would like to hear. Because it is a motion, I believe, to dismiss the counterclaim. And if it’s not dismissed, then obviously he needs to answer it because it could have some bearing on the counterclaim.

MR. BATTAGLIA: I have to check that. I understand from talking to Mr. Howie that he may have responded to that counterclaim and affirmative defenses. I’d have to check that out.

THE COURT: If he did, I haven’t seen it.

MR. DANDAR: I’m Ken Dandar, by the way. Judge, Mr. Howie filed a motion to dismiss the pending counterclaim. They never filed the new counterclaim naming Mr. Minton, so he prematurely filed a motion to dismiss. We never received a new

0263

counterclaim which is supposed to name Mr. Minton as a defendant. We’re still waiting for that.

THE COURT: Okay. I think that perhaps the reason why they didn’t file a new one is because I allowed him to be added orally, to be — to be amended, I guess. So perhaps they — I mean, Mr. Howie obviously thought it had been filed, for all intents and purposes, with the oral amendments, because he did file a motion to dismiss or something.

MR. BATTAGLIA: Your Honor, I did look. That was a problem that puzzled me a bit, because there was no order in the file, and then there was a corrective counterclaim that was filed. And I didn’t understand the import of that, because the party was just added by a corrective counterclaim without an order of the court. I assumed you had granted that orally.

THE COURT: I had. And I had granted it orally, and maybe I just forgot to sign an order. Can you all go back and maybe look into that? Because it was your motion, I believe, to add him.

MR. LIEBERMAN: Yes.

THE COURT: And I granted it. And I know Mr. Howie was here, and I said, “It’s granted and he

0264

is now a party.”

MR. LIEBERMAN: Yes. And he was allowed to sit in as a party from then on, as opposed to being excluded under the rules.

MR. BATTAGLIA: Is there presently a motion to dismiss pending?

THE COURT: Yes. That Mr. Howie has filed.

MR. BATTAGLIA: Filed on behalf of Minton?

THE COURT: Yes.

MR. BATTAGLIA: We’ll look into that.

THE COURT: It’s more than a motion to dismiss.

MR. BATTAGLIA: It is. It’s a motion to dismiss and a motion to strike.

THE COURT: Yes.

MR. BATTAGLIA: I saw that. And we’ll get back to the court.

You got to understand we’re coming in very late. There’s thousands and thousands of exhibits. And we’re just trying to catch up here.

THE COURT: Yes. There are thousands and thousands of exhibits.

MR. BATTAGLIA: It’s going to take a bit —

THE COURT: I’m sure it is.

(The reporter had technical problems and there was a pause in the proceedings.)

0265

MR. WEINBERG: Your Honor, before the break, Mr. Prince had said he was going to find the section —

THE COURT: Yes.

MR. WEINBERG: In the ethics book that said you had to get the permission of an ethics officer to testify about Scientology. Could he —

THE COURT: Did you find that?

THE WITNESS: Your Honor, I misspoke as to where the actual quote was. It’s not in the ethics book, but it is in another volume which unfortunately we do not have here, but I will get it and I will submit it to the court.

THE COURT: All right. And the same — if you can’t, why, we’ll strike that.

THE WITNESS: Okay.

BY MR. DANDAR:

Q Mr. Prince, let me show you Plaintiff’s Exhibit Number 123. Can you identify 123?

A Yes. This is a series that’s put out for the technical part of Scientology which has to do with the PC Folder and the contents of the PC folder.

Q And is this something you were trained on as a technical person in Scientology?

A Yes.

0266

Q Okay.

THE COURT: I hate to interrupt you, and I feel really bad about it.

This was laying here. I don’t know whether this is something that was previously admitted. It doesn’t have a number on it.

MR. DANDAR: This was. This was 114, which was admitted.

THE COURT: Okay. Thank you.

MR. DANDAR: I’d like to move Exhibit 123 in evidence.

MR. WEINBERG: Is it one exhibit or two exhibits? You handed me —

MR. DANDAR: Did I hand you two?

MR. WEINBERG: You handed me The PC folder and Its Contents, and Mixing Rundowns and Repairs. One was an exhibit dated November 13th, 1997, which was after Mr. Hubbard died. But I don’t have an objection to it, if you want —

THE COURT: It does look like you have two different things here.

MR. DANDAR: I have two. And I meant to do that. It involves the —

THE COURT: Well, then, how about making them A and B?

0267

MR. DANDAR: All right.

THE COURT: 123-A will be The PC folder and Its Contents; 123-B, if you’re saying it’s related, will be Mixing Rundowns and Repairs —

MR. DANDAR: Well —

THE COURT: — 123-B?

MR. DANDAR: Let’s make sure I’m right about that.

MR. WEINBERG: When I say I’m not going to object, I do have an objection to all of this and Mr. Prince testifying, but I don’t object to the authenticity of these.

THE COURT: Okay.

BY MR. DANDAR:

Q Mr. Prince, is the separate document, that apparently is paper clipped to The PC Folder and Its Contents, entitled Mixing Rundowns and Repairs — is that related to The PC folder and Its Contents or is that something different?

A That’s something different.

MR. DANDAR: Okay. Then I will withdraw that.

THE COURT: All right. So it’s just 123, The PC Folder and Its Content.

MR. DANDAR: Right.

THE COURT: Okay.

0268

BY MR. DANDAR:

Q Now, Mr. Prince, is the Church of Scientology allowed to deviate from this bulletin of November 13th, 1987 on what is supposed to be in a person’s PC folder?

A Not at all. The whole purpose of this issue is to clearly define what is expected to be in a preclear folder. It gives the significance of what each item is, in detail, and auditors — any person that audits in Scientology is trained on this as a basic for auditing.

Q Now, Mr. Weinberg brought up a good point. Mr. Hubbard died in 1986. How can this policy letter dated November of 1987 bear his stamp of approval with his name on it?

A Well, turning to the last page, it says, “This is a compilation assisted by the LRH Technical Research Compilations.” There are other — there’s another issue type that isn’t a formal issue type within Scientology, which is called advices. And often, from advices, policy letters can be compiled and issued.

Q And that’s what this is? This is a compilation?

A Correct.

MR. DANDAR: Like to move Exhibit 123 into evidence.

THE COURT: It’ll be received.

0269

BY MR. DANDAR:

Q Also Mr. Prince, I’m going to show you Exhibit 124. It’s marked for identification.

MR. DANDAR: Hand one to the court and counsel.

BY MR. DANDAR:

Q Can you identify 124?

A Yes. This is a Scientology policy directive. And this was issued from the writings of L. Ron Hubbard and authorized by the watchdog committee, adopted as church policy. This concerns confidentiality aspects of preclear folders and what’s expected to be in them.

MR. DANDAR: Okay. I’d like to move 124 into evidence.

MR. WEINBERG: No objection.

THE COURT: All right. It’ll be received.

BY MR. DANDAR:

Q Now, Mr. Prince, when you started to review Lisa McPherson’s 1995 PC folders, did you find them to be intact?

A No, I did not.

Q Did you create an affidavit which — where you disclosed things that were missing?

A Yes, I did.

THE COURT: Are we now into that part of the testimony that deals with the complaint itself?

MR. DANDAR: Yes.

0270

THE COURT: Okay.

BY MR. DANDAR:

Q Mr. Prince — and we’ve already had marked, and I believe it’s in evidence, Plaintiff’s Exhibit 108, which is your affidavit dated April 4, 2000, concerning the PC folders, and with a list of things that are missing. Do you
recall creating that affidavit?

A Yes, I do.

Q Do you need to see it to refresh your memory?

A Yes, I do.

Q Did anyone help you in creating that affidavit?

THE COURT: What was the number of Plaintiff’s Exhibit again? 108?

MR. DANDAR: Yes.

Let’s make sure it’s in evidence. I’m pretty sure it is.

THE COURT: As a matter of fact, if he’s going to be referring to it, Madam Clerk, if you could get — let me use the official copy. And I’m sure you filed mine in its appropriate book.

MR. WEINBERG: Your Honor, while she’s looking, I object to all this as to the relevance, as to what was or what was not in the PC folder.

What the hearing is about is whether or not Mr. Dandar made a sham pleading and Mr. Prince

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executed in essence a sham affidavit, accusing David Miscavige of murder, and whether or not there’s been various misconduct from the plaintiff’s side regarding various testimony in the case.

What does what was in the PC folder or not have to do with that?

MR. DANDAR: This falls under the second category in Mr. Weinberg’s comments: Various misconduct. They have accused me of lying about the fact that Lisa McPherson wanted to leave Scientology. Somehow I just made that all up and I got people to lie about it.

And that’s part of their terminating sanction motion and disqualification motion.

MR. WEINBERG: So you —

But what’s that got to do with what’s missing?

You going to ask him what was in the PC folders? Is that what you’re saying?

THE COURT: Well, there’s also an allegation as to his complaint and whether or not there’s any basis for it. And part of what I have read, maybe in Mr. Prince’s affidavit, that some of the missing data is data from the workers, which the testimony would be, from some witness — Mr. Prince, perhaps — should have been in the PC folders,

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and —

MR. WEINBERG: I mean, I — they’ve made that allegation, although the workers all testified what they did, what they saw and all that.

But that has nothing to do with whether or not David Miscavige ordered Lisa McPherson to be killed. Just —

THE COURT: Well, whether it was an intentional death, I think, is at issue here, and I think it does. So your objection’s overruled.

MR. DANDAR: Was 109 not in evidence?

THE COURT: And besides that — I don’t know what his testimony’s going to be, but if this is, in some fashion, what he relied upon for his opinion, then I think it’s got to be relevant for his opinion.

MR. WEINBERG: I thought it was inquiring. I mean, it’s —

THE COURT: I think that probably for all those different things it has some relevance, so I’m going to let it in.

MR. DANDAR: And Judge, 108’s previously been admitted into evidence.

THE COURT: Right.

BY MR. DANDAR:

Q Now, Mr. Prince, when you reviewed the files of

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Lisa McPherson, did you find routing forms?

A I did not.

Q And recently we showed you some routing forms that, within the last few weeks, that the Church of Scientology states they have reproduced to us. And did you review those?

A Yes, I did.

Q Do those routing forms have anything to do with Lisa McPherson spending six to eight weeks at the Ft. Harrison Hotel in the summer of 1995?

A No, they do not.

Q Do those routing forms have anything to do with Lisa McPherson spending 17 days at the Ft. Harrison Hotel from November 18th of ’95 to December 5th of ’95?

A No, they do not.

Q Can a person, a public member like Lisa McPherson, stay at the Ft. Harrison Hotel without a routing form?

A No, she could not.

Q What would the routing form tell us?

MR. WEINBERG: Objection. Competence. I mean, is Mr. Prince saying that he has knowledge as to what a person that checks into the Ft. Harrison Hotel has to fill out in order to be a guest there?

You have to have a routing form as opposed to registering as a guest? What basis? He never

0274

worked at the Ft. Harrison Hotel.

THE COURT: He is telling us, based on his experience in Scientology, as to what a routing form is used for and what a routing form should have on it.

MR. WEINBERG: But Mr. Dandar asked him whether you needed a routing form to be a guest at the Ft. Harrison Hotel.

MR. DANDAR: Well, let me rephrase the question.

BY MR. DANDAR:

Q Do you need a routing form, Mr. Prince, to be in a program such as the introspection rundown, whether it’s the Ft. Harrison Hotel or any other property of the Church of Scientology?

A Yes, you do.

Q And why is that?

A Because the Ft. Harrison —

And I’ll just say this: It’s incorrect that I never worked at the Ft. Harrison Hotel. I worked at the Ft. Harrison from 1979 to 1982.

The Ft. Harrison has many divisions, many departments, many sections that people come either for training or for auditing. They have different places where people would get auditing.

0275

And the whole purpose of a routing form is when a person comes in for service, they sign in, they get their hotel room, they’re routed to pay for their hotel room, they get what their room is, any questions are answered. When
they’re ready for services, they go down, they’re put on another routing form.

And like, if they’re going to get a service — a training course, a TRs course, it would be on the routing form, and they would go see the registrar; they would go and see the director of processing; maybe they would get an interview.

In other words, the routing form gives you the areas and the people that you need to see and the places you need to go to in order to accomplish what you have come for.

Q And is there any policy that permits a deviation from the requirement to have a routing form?

A No, there is not.

Q As an expert on Scientology tech, what does it mean to you that there is no routing form for Lisa McPherson?

A Well, in and of itself, that is an oddity. But when you take into consideration the fact — many other items that are missing from her preclear folder, I can only opine that this was information that would have not been good to discover for Scientology’s behalf.

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MR. WEINBERG: Objection.

BY MR. DANDAR:

Q Have you —

MR. WEINBERG: Competence, your Honor.

THE COURT: I’m going to allow it. I’m going to allow it for this hearing.

BY MR. DANDAR:

Q Have you been involved in the destruction — intentional destruction of PC folders of members, in addition to Mr. Wollersheim’s, that you previously testified about at this hearing —

A Well —

Q — which was ordered to be pulped by Mr. Miscavige?

A Well, at the time that the Wollersheim incident happened, because there were threats from other people such as John Nelson and — well, I don’t know. You know, there was a list of people at the time. The only one that I specifically recall right now is John Nelson. But their folders were destroyed as well.

Q What about Mr. Armstrong?

A Yes. His as well.

Q What about Mr. Franks?

A I believe his was as well.

MR. WEINBERG: Excuse me.

0277

THE COURT: Yeah.

MR. WEINBERG: Believe? Or does he know?

THE COURT: Do you know that or —

THE WITNESS: Your Honor, as I sit here today, I can’t say for certain —

THE COURT: Okay.

THE WITNESS: — but I knew there were certainly more than Mr. Wollersheim’s folders, because there were a list of people. And I can’t sit here and recall today every name —

THE COURT: Okay.

THE WITNESS: — that was on that list.

THE COURT: Okay.

BY MR. DANDAR:

Q What is the significance to you — let’s start with the missing — what’s missing from her folder. In the introspection rundown that Mr. Kartuzinski states she was under November 18th through December 5th of ’95, is there supposed to be documentation in a PC folder that Lisa McPherson was indeed under the introspection rundown?

THE COURT: What dates, now? Are we talking about the 17-day dates?

MR. DANDAR: Yes.

THE COURT: Okay.

0278

A Yes. There would have been, in the very front of the folder, what’s called a program. It would have been a repair program. It would have been something that’s on a pink piece of paper as opposed to a blue piece of paper.
The color in the paper — the color within the preclear folder also has significance.

But in Lisa’s case, there would have been, if she was on — on the introspection rundown, it would have given a short statement of who she was, what she’s accomplished, what her last auditing activities were, and what the current problem was, what the symptoms were that she was experiencing that would cause her to be on introspection rundown.

MR. WEINBERG: Your Honor, I have an objection to this whole line. I — I take it where he’s going is to suggest that she wasn’t on the introspection rundown, when he alleged in the complaint that she was on the introspection rundown. It’s not an issue in this case. We answered the complaint. It’s not an issue.

THE COURT: That’s true.

MR. DANDAR: I subsequently discovered that this program was missing, that Mr. Kartuzinski, under oath, said was in her PC folder. Now I’m not sure what she was going through and where she was.

0279

These things — these things are missing, and we would have to conform the pleadings to the evidence as we discover new things that are — go on.

THE COURT: So what are you saying? Are you saying that you — that she was not under the introspection rundown?

MR. DANDAR: Well —

THE COURT: Or you don’t know?

MR. DANDAR: I’m saying it’s not a confirmed fact that she was on the introspection rundown, because of what’s missing.

THE COURT: Okay. I’m going to let this witness testify at this hearing, because we need to get to where it was that he comes up with his conclusions —

MR. WEINBERG: I understand.

THE COURT: — and I assume all this has something to do with it, so —

MR. WEINBERG: I’m not sure I have the same assumption, but I understand where you’re —

THE COURT: All right.

BY MR. DANDAR:

Q In your experience in Scientology, were things that were beneficial — papers and documents that were

0280

beneficial to Scientology removed from a member’s PC folder?

A No. You know — and I’ve written a declaration about this before — well, this declaration may be in and of itself — you know, with the Wollersheim, there was the process of, “Okay, well, we’ll turn over something; we’ll go
through and we’ll — we’ll get rid of any kind of incriminating things that would incriminate Scientology.”

Then when the production of all the folders were called for, it — that became too massive of a task and it was decided to destroy them.

MR. WEINBERG: Your Honor, could I say one more thing, so I don’t lose this train of thought?

I did object, and I understand your ruling, but he already had alleged that — that the introspection rundown happened, and his response to your question and my statement was, “I just recently discovered it.”

Well, Mr. Prince reviewed the PC folders, his expert, in December of 1998, and whatever wasn’t there in December of 1998 certainly isn’t there now. So what’s he talking about?

THE COURT: I don’t know, but I think that this testimony is going to tell us why Mr. Prince concluded what he concluded, which is what Mr. Dandar relied on for his complaint. It is relevant for this hearing.

0281

Please don’t object again.

MR. WEINBERG: I’m sorry.

BY MR. DANDAR:

Q Mr. Prince, you — when did you actually sit down and review the 1995 PC folders of Lisa McPherson?

A It was in the fall of 1999.

Q What’s the date of that affidavit?

A The date of this affidavit is April — the 4th of April, 2000.

Q Okay. And concerning this one issue, the issue of whether or not Lisa McPherson was satisfied with her Scientology experience, do the PC folders reveal what she had to say about her Scientology experience in 1995?

A Yes, it does. And I think I’ve covered that with as much detail as possible: That she wanted to leave. She actually made plans to leave. And she felt like she was starting to become damaged.

Q And that’s inside the PC folders?

A Correct.

Q Now, within your experience of Scientology, have you used — have you — are you familiar with the term “end cycle”?

A Yes, I am.

Q And what is your understanding or familiarity with that term?

0282

THE COURT: Can I —

I’m sorry. I’m as bad at interrupting chain of thought as anybody.

This — this particular affidavit is the affidavit that was dealing with her wishing to leave that was part of the motion for summary judgment that was ruled on by Judge Quesada, is that right?

MR. DANDAR: Well, that was part of it, but there’s a lot more than just that in there. It talks about things that are missing from her PC folder.

THE COURT: Okay. All right. Now we’re past the missing items from the PC folder and to —

MR. DANDAR: Trying to get that paragraph 34.

THE COURT: Okay. Thank you.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Are people who want to leave the Church of Scientology — how are they looked at, within your experience and per policy by the Church of Scientology?

A Well, people who want to leave Scientology and publicly state such are considered criminals, because that’s a high crime in Scientology.

MR. DANDAR: Right. Search and Discovery is in evidence. That came out of here.

THE WITNESS: Says right here, “It is a high crime to publicly depart Scientology.” And this comes from HCO policy letter of 23 December, 1965, RB, Suppressive X, Suppression of Scientology and Scientologists.

0284

THE COURT: What page are you reading from, sir, in that book?

THE WITNESS: Where I read that quote from, I am reading from — I just read from 159.

THE COURT: Okay.

MR. DANDAR: Judge, I’ll have that entire policy marked.

MR. WEINBERG: Your Honor, my objection to this is it talks about — Mr. Prince read it –publicly — a person publicly announces he’s going to depart Scientology. Well, that’s not what we have in this case. What’s that have to do with this case?

THE COURT: I’m sorry. I didn’t hear him say “publicly.”

MR. WEINBERG: That’s what he read. That was —

THE WITNESS: It says, “It is a high crime to publicly depart Scientology.”

I think Lisa had done that, because she had told her mother and she had told a friend that she was leaving Scientology. And she made it known, in the notes that I made here, that she intended to leave. She wasn’t happy with —

MR. WEINBERG: I object to that statement

0285

because the evidence —

THE COURT: Well, look, you don’t need to object to that, because I know enough about —

MR. WEINBERG: Okay.

THE COURT: — the evidence with the mother and the evidence with the friend and the fact that what would be in her PC folder would hardly be public, where I can determine the validity of that statement.

MR. WEINBERG: Okay. All right.

BY MR. DANDAR:

Q Mr. Prince, within your experience with Scientology, what does that — what does it mean to publicly leave Scientology?

A You could publicly leave Scientology in several ways. You could submit a letter of resignation and make that letter available to other parties beyond a recant, which would — in a normal organization, would be the ethics officer.

I guess in these days and times you could go on the Internet or you could just simply announce to your friends and fellow Scientologists that you have the intention of leaving.

THE COURT: How about if I just don’t go back? I mean, if I’m a member of a church — which I was at one time when I was a child — and I just don’t

0286

go back? I mean, is that — is that leaving?

THE WITNESS: Yes. That is considered a form of leaving. And — and in that instance, if you just simply left, you would be contacted and asked to come into the organization so that they could find out what happened. If you —

THE COURT: And what if you just don’t go in?

In other words, I’m a public member, which is what Lisa McPherson was — this is a hypothetical — and I — even — I don’t want to go back and I don’t want to get any more auditing and I don’t want to go to any more services and I just don’t go?

THE WITNESS: Well —

THE COURT: They say, “Come in,” and I just decline and I don’t go.

THE WITNESS: Then they’ll show up on your door.

THE COURT: Oh.

BY MR. DANDAR:

Q Okay.

A There’s a process of getting out of Scientology. There is a way to do it. And normally, it involves signing a release agreeing that you will never — that you’ll be ineligible for Scientology services in the future —

Q To —

0287

A — and you would also have to sign a statement saying that you release any claims of any possible damage or upset that you had — in other words, a general release for the different Scientology corporations that you’ve been involved in.

MR. WEINBERG: Could we just make it clear that that’s only — that he’s talking about staff members and not public members having to sign a release?

THE WITNESS: I — it’s staff and public. I — that’s the second time I’ve said that.

BY MR. DANDAR:

Q Okay. Mr. Prince, you said that she talked to her friend from high school about wanting to leave. Where did you get that information from?

A From her testimony.

Q The friend’s testimony?

A Yes.

Q Kelly Davis?

A Yes.

Q And when you said that Lisa called her mother and said she wanted to leave. Where did you get that from?

A I think — I read — I read it — I read it somewhere in the evidence. I can’t —

Q Okay.

A — put my finger on exactly where —

0288

Q Do you recall —

A — I saw it.

Q — Lisa’s mother, Fannie, having a Hospice worker by the name Sandra Anderson?

A That’s right.

Q Is that what you’re referring to?

A Yes.

MR. WEINBERG: Your Honor, is he, like, prompting him now?

THE COURT: I would say so.

Stop leading him.

MR. DANDAR: It’s either — wanted to make sure it wasn’t from me. Because that’s the accusation.

THE COURT: Move on, Counselor.

MR. DANDAR: All right.

BY MR. DANDAR:

Q Mr. Prince, end cycle. Can you tell us what — where and when you’ve heard that or seen that term?

A End cycle has a history in Scientology. And it has varied meanings.

One meaning of end cycle is to start, change and stop something. In other words, you start it — you start an activity, you carry through to its intended result or purpose, and then you end it. So ending the cycle, you know, like this hearing is going to have an end of cycle

0289

when the judge decides who’s right and who’s wrong or discovers the issues. That’s one form of end cycle. Another form of end cycle is to die. This — this — this idea of ending cycle to die came into prominence in my mind and in my experience in Scientology after Mr. Hubbard passed in 1986 at a discussion with senior CS Ray Mithoff. Because I was curious. He sat on a deathbed with L. Ron Hubbard.

And I asked him, you know, “When he died –” I asked him, you know, because this was — L. Ron Hubbard was a person that we all looked up to. And I — and I was curious. You know, “Well, how did this man die? What were the exact circumstances? What happened there?”

And he said that he positively started shutting down certain parts of his body; his, you know, certain part of his systems.

And I asked, “Well, how does this happen? I mean, what are you — what are you doing?” And he told me the Scientology process is that you use — you know, you talk about what the — your attention may be stuck on; at what problems do you have with dying? I mean, there’s a whole procedure that you go through to prepare for death so that you have no attention or problems with death and can die.

When Mr. Hubbard passed, at that point I started seeing, you know, more of the concept of ending cycle, as

0290

far as to die.

THE COURT: Is this a little bit like a — what we might think of Hospice and how they prepare someone —

THE WITNESS: Sure.

THE COURT: — with a terminal disease in your family and —

THE WITNESS: Correct.

THE COURT: Okay.

BY MR. DANDAR:

Q Well, Mr. Hubbard didn’t have a terminal disease, though, did he?

A To my knowledge, no.

Q But he still went through that process of end cycle?

A Yes.

Q So where else did you see that term used in reference to dying?

A Terminally ill people. I’ve also read this up in affidavits.

A friend of mine, Ted Cormack (phonetic), had Hodgkin’s disease. It was apparently fatal. I saw in his folder from Mr. Mithoff the necessary steps that people do in order to, you know, give up the ghost, basically; you know, to die.

0291

THE COURT: Die in peace —

THE WITNESS: Right.

THE COURT: — like in Hospice.

THE WITNESS: Exactly.

BY MR. DANDAR:

Q Do they do that by themselves?

A No. It’s done with an auditor.

Q And did you —

THE COURT: With what, sir?

THE WITNESS: An auditor.

BY MR. DANDAR:

Q And is there ever anything in writing about having an auditor go in and assist someone to die?

A Absolutely. There would be, as in Lisa’s case, a program. That program would —

MR. DANDAR: Can I — can I please have these people stop laughing?

THE COURT: Yes.

MR. WEINBERG: We apologize.

And I object. “As in Lisa’s case, a program.” I mean, he has just said 10 minutes ago that there was no program, and therefore —

THE COURT: He is trying to tell us what he believes to be missing —

MR. WEINBERG: Well —

0292

THE COURT: — which is what he’s talking about: Missing things in the PC folder, which is what gave his opinion that he gave to Mr. Dandar, who filed the complaint.

MR. WEINBERG: But the question was, though, was generally about his understanding of end cycle, end of cycle.

THE COURT: Your objection is overruled.

And I’m going to instruct you all back there to stop laughing.

MR. WEINBERG: You’re right.

THE COURT: Go ahead, Mr. Dandar.

MR. DANDAR: Okay.

THE COURT: So it’s your belief that an auditor would have been with Lisa McPherson when she died? Is that what you’re suggesting, from this missing — missing documents, or what?

THE WITNESS: Well — well, you know, your Honor, for me that’s kind of mixing apples and oranges. Because the question he asked me was about a specific incident that happened with a fellow named Ted Cormack —

THE COURT: Right.

THE WITNESS: — so.

THE COURT: Did you see his PC folder?

0293

THE WITNESS: Yes, your Honor.

THE COURT: And what is in there?

THE WITNESS: The process is similar to what you said, in Hospice, when a person dies in peace; you know — you know, as far as they’re concerned everything’s taken care of and they can go.

THE COURT: Okay. And so that you saw that in his PC folder?

THE WITNESS: Yeah. You know —

THE COURT: And said an auditor was there?

THE WITNESS: Yes.

THE COURT: Okay. So how do you jump from there to something that’s missing in Lisa McPherson’s folder and assume that there was an auditor with her with some end cycle directive?

THE WITNESS: Well, with — and we’ll get to that too.

But in relationship to Lisa McPherson, it is — it is my belief that she was most assuredly on a program; that that program most assuredly was in her file folder at some point, along with other reports that are detailed — that are missing; and those — you know, for whatever reason, those things weren’t turned over or made available.

THE COURT: Let’s assume that — for the sake

0294

of argument, that what she was on was the introspection rundown, and that something went wrong, and she wasn’t taken to the hospital as quickly as she should have been, and she died. And let’s assume further that somehow or another somebody removed part of that from her folder. That would have nothing to do with an end cycle, an auditor being there or anything of the sort. So I guess my main question is, what caused you to leap to the conclusion that the fact that the documents were missing?

And there’s no question of that. So two and a half days, I guess of documents are missing —

THE WITNESS: Right.

THE COURT: — toward the end of this — I’ll call it an introspection rundown.

You know, how do you know that that just didn’t have something to do with the fact that either somebody, A, forgot to put them in a folder or, B, if they were destroyed it was because somebody was negligent and they didn’t want somebody to see that? How do you get to the fact that somebody ordered her death and said, “End cycle,” or whatever it is that’s in the complaint?

THE WITNESS: Okay. This is exactly how I came

0295

to the conclusion —

THE COURT: Do you mind, Mr. Dandar?

MR. DANDAR: No, no.

THE COURT: That’s what we need to get to.

MR. DANDAR: Let’s get — let’s get to it.

THE WITNESS: Let’s get to it.

THE COURT: Get to it.

How did you conclude — how did you — I presume that you read the PC folders.

THE WITNESS: Right.

THE COURT: You answered Mr. Dandar’s questions. He asked you as his consultant, “Can you tell me what you think –”

THE WITNESS: “What happened?”

THE COURT: This is what you told him, and he put it in the complaint.

THE WITNESS: Correct.

THE COURT: All right. So now you got to tell me how you came to the conclusion you came to and what it is you told Mr. Dandar —

THE WITNESS: I’ll —

THE COURT: — okay?

THE WITNESS: — tell you exactly —

THE COURT: All right.

THE WITNESS: — how I did that, your Honor.

0296

THE COURT: All right.

THE WITNESS: From reading Lisa McPherson’s preclear folders, reading her ethics folders, seeing, kind of like, what’s missing — and it didn’t make sense for these things to be out of the preclear folder unless they were damaging to the church.

And again, I’ve been in a position where, you know, it was considered documents within a preclear folder were damaging to Scientology so they’re removed for Scientology’s sake.

But even a step back from that, your Honor, you get a person —

And it clearly states on the introspection rundown that once you are assigned to the introspection rundown, you are not allowed to leave introspection rundown until the case supervisor tells you you can leave. You are literally incarcerated until you are told you can leave.

THE COURT: Well, you know, that may be your interpretation. If somebody is — is what I would consider schizophrenic or very, very mentally disturbed, you really wouldn’t want them leaving because they might be — you know —

You handled an introspection rundown, right?

0297

THE WITNESS: Sure. Yes. I’ve done them.

THE COURT: And I’ve read what — what you and Ms. Brooks said about this woman. So apparently there was a time when she was in a situation where you wouldn’t have wanted her just stumbling around the street, right?

THE WITNESS: Right. Correct.

But you know, be that as it may, again, the person is not allowed to leave until they have permission to leave.

THE COURT: Okay.

THE WITNESS: So whether or not this person experienced some lucid moment or had a lucid hour and said, “Hey, look, I just want to do something else,” they still could not leave, okay? Now, what happens in that situation, from introspection rundowns that I’ve done — that I have done, participated in myself, and myself seeing and being incarcerated — what happens?

When you’re in a situation you don’t want to be, you say — you tell them, “Look, I don’t want to be here.” “Well, too bad. You have to be here.” “No. It’s not too bad. Now, really, guys, it’s over. I just want to go.” “No. You’re not going.”

Well, what happens? It escalates. The person

0298

says, “Hey, look, if you don’t let me out of here, I’m going to call the police. If you don’t call — let me out of here, I’m going to find a way to contact law enforcement. I’m going to find a way to get out of here. You better let me out of here.” And it escalates like that. And this has happened. And the reason why I say what happened to Lisa happened to Lisa — the reason why I gave that opinion is, number one, what is missing and what would have been there, which happens as a natural consequence, is, when you’re held against your will and people don’t want to let you go, then you complain. You threaten. She threatened. Oh, no.

Now it becomes a huge problem, if Lisa is being held against her will and she wants to leave, and she’s already made it clear, through what I’ve written here, that Scientology procedures are — is not making her spiritually more able; it’s not furthering her ideas of — of, kind of, what she had in mind.

So it is my opinion that Lisa started threatening Scientology at some point. She started threatening to go to the police. She may have threatened that, “I’m going to sue you if you don’t let me go. I’m going to do whatever.” You know,

0299

push the buttons in — in the hope to get out. They didn’t let her out.

I think that Lisa became very sick. I think Lisa did change her mind about what her plans were once she left. And when — and in that horrible situation, for Scientology, it would have been a nightmare for that girl to leave that hospital — to leave Scientology and go to the hospital.

Now, this is, you know, is my opinion and I state it as such.

For them — for her to say, “Look, they locked me in there.” You know, “This happened, that happened.” And —

THE COURT: Well —

THE WITNESS: — boom —

THE COURT: — there was nothing that indicates she wanted to go to the hospital. She left — I mean, she left the hospital because she wanted to leave the hospital, so —

THE WITNESS: Yeah.

THE COURT: — if she’d left, presumably she was going to go home.

THE WITNESS: Right.

Well, you know — of course, we know that that didn’t happen.

0300

THE COURT: Well, I know. But you’re saying what a horrible nightmare it would have been. The truth of the matter is, if she had been well and had gone home to her mother and sister and what have you, there would have been no nightmare at all —

THE WITNESS: That’s —

THE COURT: — for Scientology.

THE WITNESS: — right. That’s right. It would have been fine.

But now we’re in a different situation, you see, because now she’s being held against her will. You know, you see — you see in the reports how she becomes violent.

You know, again, in my experience, as a natural progression, when you are being held and you want to be in one place and somebody’s making you stay in one place, it starts to escalate.

THE COURT: Let me ask you a question, Mr. Prince: Have you ever been in a mental hospital?

THE WITNESS: Yes.

THE COURT: So you know how, in a mental hospital, when somebody is really — I’m going to use the term “crazy,” okay? Very sick. Somebody who’s psychologically extremely disturbed.

0301

THE WITNESS: Right.

THE COURT: Well, they want to leave too, right? That’s why they have them behind locked doors and bars and all that sort of stuff, is because they want to leave.

THE WITNESS: Mm-hmm.

THE COURT: And they’re not fit to leave mentally. They would be a danger to themselves, perhaps others, to let them out in the street. So when somebody’s in a mental hospital, very sick, and they say they want to go, well, they’re not allowed to leave.

THE WITNESS: Well, you know — you know — now, let’s take a look at this.

You’re talking about a person that’s sick, right?

THE COURT: Right.

THE WITNESS: That means a medical diagnosis, right?

There is no medical diagnosis here. There is no authority that says this person was crazy. This is just the opinion, based on the beliefs of Scientology, that they gave her this label of being crazy, okay? That’s way different than being in a mental institution where you’ve been diagnosed, or

0302

you’ve committed some crime, or you’ve harmed somebody, or something has caused to you go to an institution —

THE COURT: Well —

THE WITNESS: — which —

THE COURT: — schizophrenic.

THE WITNESS: — is certainly not the case with Lisa.

THE COURT: I mean, you can be in a mental hospital and not have harmed anybody and not be a danger — I mean, you’re talking about a Baker Act, where you’re — you’re kept against your will involuntarily.

But I mean, there are sick people in a hospital, just because they’re sick and they’re crazy and they — and they just aren’t fit to be on the street, right?

THE WITNESS: Right. Right. In a hospital.

There’s a difference between being in a hospital and being locked in a room with people who don’t understand really what’s going on and are just following orders.

THE COURT: Well, they may not.

But the truth of the matter is, that’s the belief of the Church of Scientology. You were a part of it and you participated in it, right?

0303

THE WITNESS: Correct.

THE COURT: You participated in an introspection rundown with somebody who was in the same boat that Lisa McPherson was in; at least in — at times, right?

THE WITNESS: Correct.

THE COURT: Nobody ordered that this lady would end cycle that you were watching, right?

THE WITNESS: Correct.

THE COURT: Well, then, how — you see, I’m just — I’m trying to help you, here, to see if there’s any basis for this.

THE WITNESS: Okay.

THE COURT: How is it that you’ve come to this conclusion, other than just it’s — it’s one of many, many thoughts that you might have as to what might have happened?

THE WITNESS: Because based on Scientology’s own policy, the first thing you do when a person starts demonstrating these symptoms is take them to a medical doctor to ensure that the reason why these symptoms are occurring aren’t based upon some medical reason, okay?

THE COURT: Okay.

THE WITNESS: Now, this is in their own

0304

documents.

Now, why would they not do that? Why would they not do that? If their documents say if a person is demonstrably mentally ill, the first thing you do is, even in introspection rundown, is take them to the hospital.

Well, why wouldn’t you do that?

THE COURT: Because maybe —

THE WITNESS: The reason why you wouldn’t do it is because the person in — they were also telling you, “I’m going to sue you. I’m going to tell about this. I’m threatening you. You got to let me out of here.”

No, you’re not going to the hospital. Because once they go to the hospital, because they are lost.

THE COURT: Okay. But that —

THE WITNESS: They’re not going to go back to Scientology.

THE COURT: Let’s assume — Slow down.

Let’s assume, for the sake of your testimony and for the sake of your beliefs and what you told Mr. Dandar, that you are right. That Lisa was saying, “I want to leave,” and they were saying, “No, you can’t leave,” and she said, “I want to

0305

leave.” And therefore — and therefore, they didn’t take her to a medical doctor. Of course, she just came from a medical doctor where she had been seen and had been released. So that could have been one of the reasons.

However, how do you jump from that conclusion to the conclusion that somebody said, “Let her die,” or — not only, “Let her die,” but proceed to assist this along in some fashion; bring an auditor in and cause her to die?

THE WITNESS: Okay. I’ll explain to you.

THE COURT: Okay.

THE WITNESS: By their own documents, people that get into this state of mind, all of them do not live. Search and Discovery, it says some don’t make it —

THE COURT: Right.

THE WITNESS: — okay?

You have a person here who, in my opinion, based on what I’ve seen, and even the missing evidence — because you know, if everything — again, like the one that I did, okay, well, this girl didn’t want to leave. This little girl didn’t
really know what was going on.

THE COURT: Which little girl we talking about

0306

now?

THE WITNESS: Terese, the one —

THE COURT: The one that you watched.

THE WITNESS: Yeah.

THE COURT: Okay.

THE WITNESS: She didn’t know. She —

THE COURT: When you say that, you meant she was really out of it mentally.

THE WITNESS: Completely.

THE COURT: Crazy.

THE WITNESS: Crazy. Barking like a dog, you know, doing —

THE COURT: Right.

THE WITNESS: — wild things.

When she started to come out of it, she certainly wanted to leave. She was certainly demanding to leave. But she was not allowed to leave until she had signed releases that released the Church of Scientology and related organizations with any liability concerning her condition.

So in other words, she signed away, you know, “what happened to me is an anomaly. It had nothing to do with my studies and training or experience in Scientology, and they have no liability for me getting into this.” This is something that’s

0307

demanded of a person who finishes that rundown, to release any liability.

Here you have a person that isn’t in that position. And it is my belief, because there’s so many —

THE COURT: What position is she in? Tell me how her position differs from —

She’s still crazy.

THE WITNESS: Well — hold on. Because when she was released, they didn’t say she was crazy, from the hospital. That was not a diagnosis that Lisa was given when she left Morton Plant Hospital.

THE COURT: But you have to admit, from the — from the — from the reports that were in there from some of the workers, she started staring at a lightbulb; she started talking about she was L. Ron Hubbard, and she started acting crazy.

THE WITNESS: Well, that’s when they brought her in there.

THE COURT: Right. And that’s when she began the introspection rundown perhaps, right?

THE WITNESS: Well, come on, Judge. Let’s back up on this. Because you just said medically she was not diagnosed as being insane. The — the medical

0308

records didn’t say, “Hey, this is a person we got to Baker Act. This is a person that’s mentally ill.” Didn’t say that, okay? So I think it’s wrong to assume that. And the reason why I think it’s wrong —

THE COURT: Well, what —

THE WITNESS: — to assume that —

THE COURT: — was — let me ask you, Mr. Prince, what’s the difference in the lady that you took care of and how she started barking like a dog — and you say she was crazy —

THE WITNESS: Mm-hmm.

THE COURT: — and what you read in the reports of Lisa McPherson, where she was crawling on the floor, humping the floor, carrying on like a crazy person?

THE WITNESS: After she had been in their — incarcerated. And I think by the fact of incarceration, it tipped her over the edge.

THE COURT: Well, you think that same thing happened with the lady you were watching?

THE WITNESS: Huh-uh. No. I mean, she was literally sitting in a chair, you know, fine, one moment, and then the next moment somebody went over to see what she was doing and she peed herself

0309

and — you know, it was a huge difference.

THE COURT: Could that have been like Lisa McPherson, who was all right, released from the hospital, went to the Ft. Harrison, and then just kind of went like this, and all of a sudden she was crazy?

THE WITNESS: Well, you know, you could —

THE COURT: Could it be?

THE WITNESS: Not necessarily. And I’ll tell you why.

Because by the fact of incarceration, it already pushes a person further than, maybe, where they were. I mean, she’s locked in a little room.

THE WITNESS: No, no, no, no. See, that’s another myth, now. Because you’re a Scientologist it does not mean that one day you are going to know, when they lock you in a room, because you studied it, this is what they — what’s going to happen to

0310

people that do this. There is no place, no — absolutely no place that gives clear instructions on what happens to a person should they experience this and Scientology decides to take them in and put them through this routine.

You find that out after the fact, after the fact it’s been determined that you have a mental problem.

You see —

THE COURT: Well, let me ask you a question: If the church doesn’t believe in psychiatrists and psychologists and they don’t believe in mental health treatment in the — in the traditional form —

THE WITNESS: Mm-hmm.

THE COURT: Everybody knows that.

THE WITNESS: Correct.

THE COURT: That’s a very basic tenet of the church.

THE WITNESS: Right.

THE COURT: Okay. It would be like a Christian Scientist. They would know that they don’t believe in medical treatment, at least in part. So if you’re a member of the Christian Scientists, you know that you believe that.

THE WITNESS: Right.

0311

THE COURT: Okay. Well, there has to be some folks that become mentally deranged, who are Scientologists, so they know that there’s some other treatment, just like you would know, if you were in the — in the Christian Scientists, if there’s a belief of laying on of hands and God will heal you — So they’ve got to be told there’s some substitute for somebody —

THE WITNESS: Your Honor —

THE COURT: — that has a mental lapse.

THE WITNESS: Your Honor, they’re not. They are not told that. It’s just simply not true. You don’t find it out until after the fact. There’s no course —

Say I’m a public member of Scientology, wants to do auditor training up to class 4. They go and they train and they — they get their certificates and stuff like that. There is no class that says, “Okay. If this happens to you, this is the exact procedure.”

That was something that was developed during the time when the introspection first came out. But then this is something that moved totally off and away from anything that public people could see or

0312

even staff would know. They were isolated and hidden from view.

And then normally, the person doesn’t do any more Scientology after introspection rundown. And I know several cases after that — of that.

Because they make you sign waivers and releases which say, “The church did not cause your condition. The church did not contribute to your condition. The church is not liable or responsible for what happened to you.”

And you agree to that, and you sign it, and then you’re on your way.

THE COURT: Okay. Well, like the lady did in your case.

THE WITNESS: Correct.

THE COURT: But she is a Scientologist.

THE WITNESS: Yes.

THE COURT: Okay. So — so — Okay. I understand what you’re saying; that — that perhaps Lisa McPherson didn’t know what was going to happen to her, is what you’re basically saying.

THE WITNESS: None of them do.

THE COURT: Okay. Now — okay. I’ll take your word for that for the sake of your testimony. How do you get from that — okay. Let’s assume

0313

there was some gross negligence going on here. She wanted to leave.

THE WITNESS: You —

THE COURT: Which there’s already been a judge that says there’s none of this. But let’s assume that she says, “I want to leave.” They say, “You’re not going to leave.” “I want to leave.” “You’re not going to leave.”

One of two things happened to Lisa McPherson, based on her doctors and her experts and the experts for the church: Either she became severely dehydrated and that caused this embolism to break loose and it damaged her lungs and she became unable to breath, I guess, and she died; or there was no real dehydration connected with it, except perhaps slight, and the same embolism broke loose and lodged in her lung in some fashion and she died.

THE WITNESS: Right.

THE COURT: So it’s one or the other. One or the other things happened to her, medically —

THE WITNESS: Right.

THE COURT: — okay?

THE WITNESS: Right.

THE COURT: Now — so that’s a given, okay?

THE WITNESS: Right.

0314

THE COURT: So how do you leap from the fact, in your mind, she wanted to leave and they said, “No,” to the fact that she died from one of those causes, through anything other than either no negligence, slight negligence, or really gross, flagrant negligence? How do you jump from point A to point B by saying that David Miscavige said, “Kill this woman”?

THE WITNESS: Or, “Let her die.”

THE COURT: Or, “Let her die”?

THE WITNESS: Okay. Now, you got to listen.

I’m going to explain this to you, okay?

THE COURT: Okay. I’m listening.

THE WITNESS: Now, again by their own policy, this woman first should have been examined by a medical doctor to see if the insanity itself was coming as a result of some medical condition.

THE COURT: Okay.

THE WITNESS: That was not determined when she went to the hospital because it was determined she was not insane.

So if she did get worse when she was at the Ft. Harrison, then the next thing that they should have done was to take her to get her medically examined to see if there was a medical reason for this

0315

behavior.

THE COURT: And you did that in your case? In the case where you handled the introspection rundown?

THE WITNESS: No.

Oh, yeah. They had a doctor come out. Sure. They had a doctor come out. Dr. Gene Dink came out to be with her. He examined her.

THE COURT: Was this a real doctor?

THE WITNESS: Yes.

THE COURT: I mean — by that I mean a licensed doctor? ‘Cause they had doctors with Lisa McPherson too, except they weren’t —

THE WITNESS: This was —

THE COURT: — licensed.

THE WITNESS: — L. Ron Hubbard’s doctor, your Honor.

THE COURT: Okay. Well, was this a licensed doctor?

THE WITNESS: Yes. Dr. Gene Dink, Los Angeles, California.

THE COURT: Okay.

THE WITNESS: Worked with the one that we have.

THE COURT: So — so as I recall, Ms. Arundo (sic) — and I may be wrong on this, but as I recall

0316

she was a doctor licensed somewhere else. There was another doctor, one — the head of the medical liaison, who had been a doctor.

MR. DANDAR: And lost her license.

THE COURT: And lost her license.

MR. DANDAR: Arrunada’s from Mexico and was never licensed.

THE COURT: Okay. But Ms. — but what’s Ms. — please give me the name.

MR. DANDAR: Johnson.

THE COURT: Ms. Johnson was a physician who had lost her license, who presumably was in charge. But — okay. You say they should have taken her to a doctor.

THE WITNESS: Yeah. They —

THE COURT: Or had a doctor come in.

THE WITNESS: Right.

THE COURT: Like they did in your case.

THE WITNESS: Right.

THE COURT: Your case, meaning the case where you were directly involved.

THE WITNESS: Correct.

THE COURT: And they didn’t do that. Okay. What else?

THE WITNESS: Well, we have to wonder why they

0317

didn’t do that.

Now, I hate to be — your Honor, you know, irrespective of what the defendants believe in this case, it brings me no great joy to — to malign them or say horrible things about them.

But because I’ve been there and because I’ve seen what happens and because I’ve seen what they do, it is my belief because when they brought this girl back from the hospital, she was not insane. She wasn’t diagnosed as that. She went insane there. She wanted to leave. She said, “I want to go.” They said, “No, you can’t go. You got a problem. We’re diagnosing you. Forget what the doctor said. We’re going to do it.”

THE COURT: Okay.

THE WITNESS: She began to struggle. She began to fight. At that point, it becomes a OSA matter. It was already an OSA matter.

THE COURT: I’m sorry. A what matter?

THE WITNESS: O-S-A. OSA. Office of —

THE COURT: OSA.

THE WITNESS: — Special Affairs matter.

THE COURT: Okay.

THE WITNESS: For several reasons now: One, because she apparently left the hotel,

0318

drove around and had a minor accident, took her clothes off, told people that she needed help.

Okay. That in and of itself was something that drew attention to Scientology that was non-optimum. And in Scientology, that is called a flap. An unpredicted activity that now involves Scientology’s reputation somehow.

Now, here is a person, Lisa McPherson, who just two months earlier attested to the state of clear. She stood in front of every Scientologist at the mecca of technical perfection, their highest level, their highest office of — of tech, and told everyone that, “I no longer have a reactive mind. I no longer have,” you know, “have problems with the past that now come up. I’m totally free from the past and I’m ready to move on.”

In other words, she was what they call in Scientologist (sic) — not a Homo sapien, but they call it a Homo novis. Homo novis in Scientology is a step above Homo sapiens.

So now this person is literally a demigod two months ago. Now she’s screaming in a room, insane, crazy.

This is a problem. This is a problem that this woman took her clothes off, walking down the street, and — and OSA had to get involved and, you know, they rushed down there, “Oh, my God.” They bring

0319

her back. She’s not diagnosed as being crazy. They just give her — she wants to get some help. She’s got something on her mind. Okay. So she comes back.

It is my contention that she wanted to leave, just like she had been saying. And they said, “No.” And they put her on the introspection rundown and she went over the edge and she got crazy. Well, before that she made many threats.

Now, it is Scientology’s belief that once you start these processes — once you start any process in Scientology, you take it to the end. It’s called processing. The way out is the way through. What turns it on or turn it off. Get the preclear through it. Whatever. In other words, keep that auditing going until the end result happens.

THE COURT: Or get the person in the introspection rundown fit for auditing. That is part of the preliminary process.

THE WITNESS: Well, the person is fit for auditing after they’ve had one eight-hour period of sleep. Okay? You got — you know, you got that step 0, step 00.

THE COURT: Right.

THE WITNESS: The first thing that normally

0320

happens with a person that gets into that state of mind, they don’t sleep for days, they can’t sleep, they’re up — a part of auditing in Scientology is, you have to have had sufficient rest to get audited.

So —

And again, in the instance where I did introspection rundown with the person, the first time that woman — after she was given Valium or whatever they gave her to put her to sleep, the first time she had an 8-hour period of time to sleep —

(The reporter interrupted.)

THE WITNESS: I’m sorry.

MR. DANDAR: Slow down.

THE REPORTER: After they gave her —

THE WITNESS: — or chloral hydrate or whatever they give them to go to sleep, the first time eight hours pass and that person wakes up, the auditor is there immediately to start.

THE COURT: I think they tried to bring an auditor into Lisa McPherson and she wasn’t capable.

THE WITNESS: Well, I heard —

THE COURT: I mean, I think I remember that.

THE WITNESS: — I heard the story that, you know, she licked the cans and — you know, that

0321

means nothing.

An auditor is trained — I don’t care if you take the cans and throw them across the room. An auditor is trained to stand up, take those cans, put them back in the person’s hands and get them to do what you want them to do. It’s called model session. You know, that’s part of the same —

THE REPORTER: Slow down, please.

THE WITNESS: — auditor series you have. Model session. Which talks about how to conduct a session.

THE COURT: That’s tough to do if the person is still in a psychological state, that’s crazy.

THE WITNESS: Well, you know — and you’re assuming that that’s the case. But the doctor didn’t assume that when she was let out.

THE COURT: Well, I’m assuming that’s the case because of the reports I read.

THE WITNESS: You know — well, you know, after —

THE COURT: Just like I’m assuming the lady that you watched after, when she barked like a dog and carried on, was crazy; like Stacy Brooks said she was crazy and like I think you said she was crazy.

0322

THE WITNESS: Right.

THE COURT: Crazy in the sense that I know — would think someone was crazy; not medically.

THE WITNESS: A danger to themselves or other people.

THE COURT: Not somebody you would want out on the street.

THE WITNESS: Right.

Okay. So again, she is in a situation now where she’s drawn into the local public attention. They’ve been promised by the doctors that she’ll be okay. Turn her over to Judy Fontana. They don’t turn her over to Judy. Because I think these things all mean in some way she was not agreeing with what was happening to her. And because she wasn’t agreeing and she wanted to leave, it got wild. It intensified.

Now, Scientology’s belief is, you know —

THE COURT: I think I can go along with you there. I mean, I think that there’s enough in that folder to realize she was not thinking clearly. She may have wanted to leave. You know, the lady you took care of may have wanted to leave. I mean, they — they act irrational, right?

THE WITNESS: Right.

0323

THE COURT: And the idea is they can’t leave.

THE WITNESS: Right.

THE COURT: Okay. So let’s say I accept that —

THE WITNESS: Right.

THE COURT: — okay? She wants to leave, they’re saying, “No, you’re not able to leave yet.”

She’s getting more and more upset.

THE WITNESS: Right.

THE COURT: She wants to leave.

How do we know they’re still not trying the introspection rundown to make her well?

THE WITNESS: I think —

THE COURT: What —

THE WITNESS: — they were doing it.

THE COURT: Sure.

THE WITNESS: I think —

THE COURT: So —

THE WITNESS: — they were doing it. But I think that she had decided she had had enough. You see — and the reason why I say that is because, if you look at this affidavit, she keeps telling them, “I had enough. I don’t want any more auditing. This is aggravating my condition. It’s making me worse.”

This is what she’s saying in her

0324

own words, the only thing she was able to say before she died. And in which whole thing, if you read this line by line in the preclear folder, “This is making me worse. I’m not getting better.”

So what do they do? Give her more auditing. Well, she doesn’t want that.

THE COURT: I will say, for the sake of this hearing, that I — I can accept that.

THE WITNESS: So because she doesn’t want it, and because she has no way to leave, because she’s actually under guard — I mean, we have a statement by Paul Kellerhals where he actually jumps on top of her and holds her down. You know, you have people not speaking to a person, keeping her in a room — I mean, that, to me, in retrospect, after my Scientology experience, is something that would make a person, if they weren’t over the edge, would certainly push them over the edge.

THE COURT: But you did that when you took care of the lady you took care of.

THE WITNESS: No. I talked to her. I did not not talk to her.

THE COURT: Was that — were you breaking the rules?

THE WITNESS: Yes. I was breaking the rules.

0325

THE COURT: Well, you don’t know that somebody else might not have broken the rules.

THE WITNESS: Well, I don’t know that either.

THE COURT: All right. So let’s take — we really need to break for lunch.

But let’s assume for the sake of argument that you are correct. She wants to leave. They say, “No.” She wants to leave, they say, “No.” And let’s assume that they’re saying “no” because they believe that she’s not finished the introspection rundown, and they’re going to get her finished.

Just like —

THE WITNESS: Yeah. And they do believe that.

Right.

THE COURT: All right. So now, one of two things happens at some point in time: Either she’s not getting enough water, right; and so she’s not getting enough water or whatever, and they should have known better, and they should have given her more water, and she reaches this miserable state and dies.

Or she is getting enough water and a pulmonary — you know, an embolus in her leg breaks loose, goes to her lungs and kills her. One of those two things happened at the end of this. And it was — it was from the embolism, right?

0326

And you wouldn’t have known that. They wouldn’t have known that. There wasn’t a worker there that would have known that. Nobody. These are the silent — silent killers —

THE WITNESS: Right.

THE COURT: — okay?

So one of those two things happened, and that’s a fact.

How do you reach the conclusion that anywhere along the line it was, “We’re going to keep her here until the embolism we don’t even know about breaks loose”?

THE WITNESS: Well, you know, that’s ridiculous, your Honor.

THE COURT: Of course it is.

THE WITNESS: Let me — you got to let me finish —

THE COURT: Okay.

THE WITNESS: — the whole thing.

THE COURT: I’m going to do that, but we’re going to take a lunch break first —

THE WITNESS: Okay.

THE COURT: — all right?

All right. It’s 12:20. Let’s be in recess until 1:30.

0327

(A recess was taken at 12:23 p.m.)

0328

REPORTER’S CERTIFICATE

STATE OF FLORIDA )
COUNTY OF PINELLAS )

I, Donna M. Kanabay, RMR, CRR, certify that I was authorized to and did stenographically report the proceedings herein, and that the transcript is a true and complete record of my stenographic notes.

I further certify that I am not a relative, employee, attorney or counsel of any of the parties, nor am I a relative or employee of any of the parties’ attorney or counsel connected with the action, nor am I financially interested in the action.